Unlike a skilled home health agency, and those skilled agencies which are Medicare certified, Florida non-skilled home health agencies are not specifically required by Florida Statutes or Rules to have and maintain a quality assurance program, (QAP), or any process for examining the consistency of compliance with statutes and rules. Even though there is lack of definition from the statutes or rules which AHCA can enforce in this regard for a non-skilled home health agency, that does not mean that these types of agencies should not have a well-crafted and vigorously implemented QAP.
The Florida Administrative Code defines a quality assurance program as follows:
“Quality assurance plan” means a plan which is developed and implemented by a home health agency to review and evaluate the effectiveness and appropriateness of service provision to patients and, upon identification of problems, requires specific action to correct the problems and deficiencies.
Merriam-Webster defines “quality assurance” as:
“a program for the systematic monitoring and evaluation of the various aspects of a project, service, or facility to ensure that standards of quality are being met.”
A QAP should have two perspectives: the overall processes of the agency that tie to administrative rules and/or best practices set out in policy, and the detailed aspects of key processes. The goal of a robust QAP is to minimize the potential for deficiencies that may result in fines, sanctions and potentially dangerous gaps in care. Of course, no one is perfect and time constraints, training failures and just human error can cause lapses in process, but by means of the QAP, you can spot instances of deviation from the proper manner of work or errors, investigate the reason for the errors and correct the process or provide training on the correct manner of work.
Some agencies believe the goal is to not show any errors, and they circumvent a valid review by correcting failures so the audits can show perfection. This is not reality and surveyors – who have walked in the agency administrator’s shoes – will be suspicious. The QA process, in actuality, shows that you’re watching the processes that are important, that you follow a plan when you find a deviation, and you are quick to correct behavior.
Think of a QAP like homework in school: you have to do it every day and if you don’t, you will fall behind with a backlog of work to do AND you will fail the test because you are not prepared. In the next installments on this topic, we will focus on two major subjects of a QAP: personnel and patient care.