Author: Sher Johnson, RN, COS-C


The final rule revised the conditions of participation (CoPs) that home health agencies must meet in order to participate in the Medicare and Medicaid programs.


Effective on July 13, 2017, the Agency must be in compliance with changes made regarding the Home Health Aide. There were many changes in regards to who can supervise, who can assign duties to the Aide, elements to be evaluated in the Aide supervisory visit, training requirements, the Competency Skills Checklist and a new requirement for an on-site annual visit while the Aide is performing patient care.


Additions to Aide training included “recognizing and reporting changes in skin condition”. The Aide will need additional training before July 13, 2017. In-service training may be offered by any organization and must be supervised by a Registered Nurse.


Changes to the Skills Competency Checklist and assessing the Aide while performing tasks with a patient now includes:

  • Assessment of communication skills, including the ability to read, write, and verbally report clinical information to patients, representatives, and caregivers, as well as to other Agency staff.
  • Assessing the Aide while performing all methods of shampooing and not just one method only with wording changed to “AND” instead of “OR”.
  • Assessing the Aide while performing all methods of bathing including “Sponge”, “Tub” and “Shower” instead of only one of these methods with wording changed to “AND” instead of “OR”.


A registered nurse or other appropriate skilled professional must make an annual on-site visit to the location where a patient is receiving care in order to observe and assess each aide while the Aide is performing care.


Be prepared on July 13, 2017 and ensure that Aides have received training on “recognizing and reporting changes in skin condition”, and that the skills competency checklist has been completed for all required elements including assessing the Aide performing all methods of shampooing, all methods of bathing and assessing communication skills. Ensure that it is documented. Any RN can assess the “Aide Skills Competency Checklist”.


JCC has revised the HR policies, Aide Job Description, Aide Skills Competency Checklist and Supervisory Visit Form to be compliant with CoPs. Check with your software vendor to ensure that the Aide Supervisory Visit Form will be revised to meet the new standards and that the Therapist can complete the Aide Assignment/Care Plan and the supervisory visit when appropriate.


Ref: §484.80 Condition of participation: Home health aide services