home health agency updated conditions of participation and

Cabinet for Health and Family Services

Office of Inspector General

Division of Health Care

Home Health Agency Updated

Conditions of Participation

and Survey Process

Presenter:

Sandra Houchen, RN, BSN

Director of Health Care

HHA CoPs

Cabinet for Health and Family Services 2

Revised HHA CoPs

• The current CoPs have been in effect since 1987, with the exception of

the patient assessment requirements, which were added in 1999.

• The new CoPs focus on:

– Safeguarding patient rights.

– Patient-centered assessment, care planning, service delivery, and

quality assessment and performance improvement (QAPI).

– Reducing the focus on administrative process requirements, and

placing emphasis on patient care and outcomes.

– The interaction of skilled professionals in meeting patients’ needs.

• The requirements went into effect January 13, 2018, for all Medicare-

certified HHAs.

• The full text of the regulations is located at

https://gpo.gov.fdsys/pkg/FR-2017-01-13/pdf/2017-00283.pdf


Organization of the HHA CoPs

• The regulations have been substantially

reorganized, and the structure of the

regulations has changed.

• The CoPs directly related to patient care are

now grouped at the beginning of the

regulation, Part 484, under nine conditions.

• The CoPs that address administration are

now in a separate subpart, “Organizational

Environment,” under five conditions.


Patient Services Crosswalk


Patient Services Crosswalk (cont.)


§484.2 Definitions: Branch Office

• The definition of “branch office” has been modified:

– The major difference is that the prior definition stated that

the branch is “located sufficiently close to share

administration, supervision and service . . .”

– While the stipulation “sufficiently close” has now been

removed, the parent must still be able to respond to the

needs of the branch and provide human resources when

any issues arise in the branch.


§484.2 Definitions: Subunits

• Subunits are eliminated as an HHA administrative category.

• As of January 13, 2018, existing subunits will automatically become free-

standing HHAs, unless they notify the appropriate State Survey Agency

(SA) and Medicare Administrative Contractor (MAC) that they wish to

become a branch of the parent HHA.

• These former subunits (which already operate under a distinct provider

number) will need to ensure that they implement an independent

governing body and administration.

• See Survey & Certification (S&C) Memo 18-03-HHA.


§484.2 Definitions: Representative

• “Representative” is defined in a way that enables the patient

to identify his or her representative, if he or she wishes to do

so:

• The patient’s legal representative, such as a guardian,

who makes health care decisions on the patient’s behalf,

or a patient-selected representative who participates in

making decisions related to the patient’s care or well-

being, including, but not limited to, a family member or an

advocate for the patient.

• The patient determines the role of the representative to

the extent possible.


New Home Health Agency CoPs


New CoP: §484.65 Quality Assurance and

Performance Improvement (QAPI)

• An HHA must develop, implement, evaluate, and maintain an

effective, ongoing, HHA-wide, data-driven QAPI program.

• The HHA’s governing body must ensure that the program reflects

the complexity of the HHA’s organization and services; involves all

HHA services (including those services provided under contract or

arrangement); focuses on indicators related to improved

outcomes, including the use of emergent care services and

hospital admissions and readmissions; and takes actions that

address the HHA’s performance across the spectrum of care,

including the prevention and reduction of medical errors.

• The HHA must maintain documentary evidence of its QAPI

program and be able to demonstrate its operation to CMS.


New CoP: §484.65 QAPI—Five Standards


New CoP: §484.70 Infection Prevention and Control


New CoP: §484.102 Emergency Preparedness

• An HHA must comply with all applicable Federal,

state, and local emergency preparedness

requirements. It must establish and maintain an

emergency preparedness program that meets the

requirements of this section.

• The source of guidance in regard to this

requirement is the State Operations Manual (SOM),

Appendix Z.


Revised and Reorganized HHA CoPs

22


§484.50 Patient Rights—Revisions

• Revised under six standards:

–§484.50(a) Standard: Notice of rights.

–§484.50(b) Standard: Exercise of rights.

–§484.50(c) Standard: Rights of the patient.

–§484.50(d) Standard: Transfer and discharge.

–§484.50(e) Standard: Investigation of complaints.

–§484.50(f) Standard: Accessibility.

• The requirement under §484.10(c)(2)(ii) relating to advance

directives has been removed; the plan of care should include

information related to advance directives (§484.60(a)(2)(xv)).


§484.50 Patient Rights—Revisions (cont.)

• §484.50(a) Standard: Notice of rights—The revisions in

this condition specify the written and verbal notification that

must be provided to the patient and the patient’s legal

representative (when applicable). Revisions to the written

notification requirements include the addition of:

–The patient’s rights and responsibilities and the HHA’s transfer and

discharge policies, in a manner that is understandable to persons who

have limited English proficiency, and accessible to individuals with

disabilities.

–Contact information for the HHA’s administrator.

• §484.50(b) Standard: Exercise of rights—Specifically

addresses a patient’s legal capacity (rather than

competence) to make health care decisions in three

elements.


§484.50 Patient Rights—Revisions (cont. 1)



• NEW §484.50(d) Standard: Transfer and discharge—Seven new requirements regarding an HHA’s policies for transfer and discharge. The HHA may transfer or discharge the patient only if:

1. The transfer or discharge is necessary for the patient’s welfare because the HHA can no longer meet the patient’s needs, based on the patient’s acuity, the HHA must arrange a safe and appropriate transfer to other care entities.

2. The patient or payer will no longer pay for the services provided by the HHA.

3. The measurable outcomes and goals for the patient have been achieved.

4. The patient refuses services or elects to be transferred or discharged.

5. The behavior of the patient (or other persons in the patient’s home) is disruptive, abusive, or uncooperative to the extent that delivery of care to the patient or the ability of the HHA to operate effectively is seriously impaired; the regulations specify four actions the HHA must take before discharging a patient for cause.

6. The patient dies.

7. The HHA ceases to operate.



• §484.50(e) Standard: Investigation of complaints.

(i) Investigate complaints made by a patient, the patient’s

representative (if any), and the patient’s caregivers and

family, including, but not limited to, the following topics:

(A) Treatment or care that is (or fails to be) furnished, is furnished

inconsistently, or is furnished inappropriately.

(B) Mistreatment, neglect, or verbal, mental, sexual, and physical

abuse, including injuries of unknown source, and/or

misappropriation of patient property by anyone furnishing services

on behalf of the HHA.



• NEW §484.50(f) Standard: Accessibility.

Information must be provided to patients in plain language and in a manner that is accessible and timely to persons with disabilities and persons with limited English proficiency, at no cost to the individual.


§484.55 Comprehensive Assessment of Patients

A new standard, §484.55(c), incorporates much of the prior condition statement, the drug regimen review, and the incorporation of Outcome and Assessment Information Set (OASIS) items and specifies the minimum requirements for the content of the comprehensive assessment.

•§484.55(a) Standard: Initial assessment visit. (No change)

•§484.55(b) Standard: Completion of the comprehensive assessment. (No change)


§484.55 Comprehensive Assessment of Patients (cont.)

• NEW §484.55(c) Standard: Content of the comprehensive assessment. The comprehensive assessment must accurately reflect the patient’s status, and must include, at a minimum, the following information…

• §484.55(d) Standard: Update of the comprehensive assessment. (No change)


§484.55(c) Standard: Content of the Comprehensive

Assessment

• NEW§484.55(c) Standard: Content of the comprehensive assessment. The comprehensive assessment must accurately reflect the patient’s status, and must include, at a minimum, the following information:

§484.55(c)(1) The patient’s current health, psychosocial, functional, and cognitive status.

§484.55(c)(2) The patient’s strengths, goals, and care preferences, including information that may be used to demonstrate the patient’s progress toward achievement of the goals identified by the patient and the measurable outcomes identified by the HHA.


§484.55(c) Standard: Content of the Comprehensive

Assessment (cont.)

§484.55(c)(3)The patient’s continuing need for home care.

§484.55(c)(4) The patient’s medical, nursing, rehabilitative, social, and discharge planning needs.

§484.55(c)(5) A review of all medications the patient is currently using in order to identify any potential adverse effects and drug reactions, including ineffective drug therapy, significant side effects, significant drug interactions, duplicate drug therapy, and noncompliance with drug therapy.

§484.55(c)(6) The patient’s primary caregiver(s), if any, and other available supports, including their: (i) Willingness and ability to provide care; and (ii) Availability and schedules.


§484.55(c) Standard: Content of the

Comprehensive Assessment (cont. 1)

§484.55(c)(7) The patient’s representative (if any).

§484.55(c)(8) Incorporation of the current version of OASIS items, using the language and groupings of the OASIS items, as specified by the Secretary. The OASIS data items determined by the Secretary must include: clinical record items, demographics and patient history, living arrangements, supportive assistance, sensory status, integumentary status, respiratory status, elimination status, neuro/emotional/behavioral status, activities of daily living, medications, equipment management, emergent care, and data items collected at inpatient facility admission or discharge only.


§484.60 CoP: Care Planning, Coordination of

Services, and Quality of Care

• Expanded from three to four standards.

• More specificity for plan of care contents; minimum requirements for the plan of care expanded from 13 to 16 components.

• Physician order authentication requirement.

• Review of the plan of care expanded to include communicating changes to the patient, patient caregiver, and representative, if applicable, as well as physicians.

• New standard added to specify coordination of care requirements (adapted from §484.14(g), Coordination of Patient Services).



Services, and Quality of Care (cont.)

• §484.60(a) Standard: Plan of care.

• §484.60(b) Standard: Conformance with physician orders.

• §484.60(c) Standard: Review and revision of the plan of care.

• NEW§484.60(d) Standard: Coordination of care.



Services, and Quality of Care (cont. 1)

Changes to §484.60(a) Standard: Plan of care:

• The requirement now includes 16 items for the plan of care. Items in the plan of care that have been changed are:

–A description of the patient’s risk for emergency department visits and hospital readmission, and all necessary interventions to address the underlying risk factors.

–Patient and caregiver education and training to facilitate timely discharge.

–Patient-specific interventions and education; measurable outcomes and goals identified by the HHA and the patient.

–Information related to any advance directives.

• Specifies that all patient care orders, including verbal orders, must be recorded in the plan of care.




• NEW§484.60(d) Standard: Coordination of care.

― Coordination of care currently under CoP §484.14, Organization and Administration of Services.

― Ensure communication with all physicians involved in the plan of care.

― Integrate orders from all physicians involved in the plan of care to ensure the coordination of all services and interventions provided to the patient.




— Integrate services, whether services are provided directly or under

arrangement, to ensure the identification of patient needs and

factors that could affect patient safety and treatment effectiveness

and the coordination of care provided by all disciplines.

— Coordinate care delivery to meet the patient’s needs, and involve

the patient, representative (if any), and caregiver(s), as

appropriate, in the coordination of care activities.

— Ensure that each patient, and his or her caregiver(s) where

applicable, receive ongoing education and training provided by the

HHA, as appropriate, regarding the care and services identified in

the plan of care. The HHA must provide training, as necessary, to

ensure a timely discharge.


§484.75 Skilled Professional Services—

Substantially Revised

• Combines and revises:

– §484.30 Condition: Skilled nursing services.

– §484.32 Condition: Therapy services.

– §484.34 Condition: Medical social services.

• Requirement specifies nine responsibilities of skilled professionals; responsibilities are the same for all disciplines.

• Specifies the supervisory responsibilities for skilled professional assistants.


§484.75 Skilled Professional Services: Three

Standards


§484.80 HH Aide Services—Expanded and Revised


§484.80 HH Aide Services—HH Aide

Qualifications• §484.80(a)(1) Standard: Home health (HH) aide qualifications. These requirements describe

the four methods that an agency may use to determine the qualifications of HH aides:

(i) Refers to when the HHA itself provides the HH aide training and performs the competency testing.

(ii) Refers to verifying the HH aide qualification through a competency evaluation only; this assumes that the candidate has had some training in the past that addresses all or some of the topics in paragraph (b) of this section, but the training content and duration did not meet the requirements in paragraph (b) of this section.

(iii) Part 483 refers to the requirements for states and long term care facilities, Subpart D, 151–154 specifies the requirements that must be met by states and state agencies for nurse aide training. Therefore, a certified nursing assistant who has taken the approved course, passed the written exam, and is found to be in good standing in the state nurse aide registry, is considered to have met the training and competency requirements for an HH aide.

(iv) If a state administers a program that licenses or certifies HH aides that meet or exceed the requirements under paragraphs (b) and (c) of this section, that program meets the requirement of HH aide qualifications.


§484.80 HH Aide Services—HH Aide

Qualifications (cont.)

• §484.80(a)(2) If there has been a 24-month lapse in furnishing services for compensation, the individual must complete another program, as specified in paragraph (a)(1) of this section, before providing services.(Moved from personnel qualifications)


§484.80 HH Aide Services—Content of

Training

• §484.80(b) Standard: Content and duration of HH aide classroom and supervised practical training. ‒There is no change in the duration of the training; it remains a total of 75 hours, with 16 hours of classroom and 16 hours of supervised practical training.

― Some changes in the HH aide training program content—13 previous topics have expanded to 15 topics. The major changes are:

Appropriate and safe techniques in performing personal hygiene and grooming tasks that include . . . (B) Sponge, tub, and shower bath; (C) Hair shampooing in sink, tub, and bed.

NEW Recognizing and reporting changes in skin condition.

The HHA is responsible for training HH aides, as needed, for skills not covered in the basic checklist.


§484.80 HH Aide Services—Competency Evaluation


§484.80 HH Aide Services—In-Service Training


§484.80 HH Aide Services


§484.80 HH Aide Services—Assignments and Duties


§484.80 HH Aide Services—Supervision


§484.80 HH Aide Services—Supervision (cont.)


§484.100 CoP: Compliance with Federal,

State, and Local Laws and Regulations

Two new standards:

• NEW §484.100(b) Standard: Licensing. The

HHA, its branches, and all persons furnishing

services to patients must be licensed,

certified, or registered, as applicable, in

accordance with the state licensing authority

as meeting those requirements.


§484.100 CoP: Compliance with Federal,

State, and Local Laws and Regulations (cont.)• NEW§484.100 (c) Standard: Laboratory services. (Formerly under 484.14(j),

Organization, Services, Administration)

§484.100(c)(1) If the HHA engages in laboratory testing outside of the context of

assisting an individual in self-administering a test with an appliance that has

been cleared for that purpose by the Food and Drug Administration (FDA), the

testing must be in compliance with all applicable requirements of part 493 of this

chapter.

The HHA may not substitute its equipment for a patient’s equipment when

assisting with self-administered tests. If the HHA refers specimens for laboratory

testing, the referral laboratory must be certified in the appropriate specialties and

subspecialties of services in accordance with the applicable requirements of part

493 of this chapter.

§484.100(c)(2) If the HHA refers specimens for laboratory testing, the referral

laboratory must be certified in the appropriate specialties and subspecialties of

services in accordance with the applicable requirements of part 493 of this

chapter.


§484.105—Organization and Administration of

Services

• Incorporates the current distinct CoP §484.38, Outpatient Therapy Services, as a standard within this requirement.

• Revises the title of “Supervising Physician or Registered Nurse” to “Clinical Manager.”

• New standard specifying the parent—branch office relationship.

• Expands requirements for services under contract.



Services (cont.)

• §484.105(a) Standard: Governing body. (Revised)

A governing body (or designated persons so functioning) must assume full legal authority and responsibility for the agency’s overall management and operation, the provision of all HH services, fiscal operations, review of the agency’s budget and its operational plans, and its QAPI program.



Services (cont. 1)

§484.105(b) Standard: Administrator. (Revised)

§484.105(b)(1) The administrator must:

(i)Be appointed by and report to the governing body.

(ii) Be responsible for all day to day operations of the HHA.

(iii) Ensure that a clinical manager as described in paragraph (c) of this section is available

during all operating hours.

(iv) Ensure that the HHA employs qualified personnel, including ensuring the development

of personnel qualifications and policies.

§484.105(b)(2) When the administrator is not available, a qualified,

predesignated person, who is authorized in writing by the administrator and

the governing body, assumes the same responsibilities and obligations as

the administrator. The predesignated person may be the clinical manager as

described in paragraph (c) of this section.

§484.105(b)(3) The administrator or a predesignated person is available

during all operating hours.



Services (cont. 2)

• NEW §484.105(c) Standard: Clinical manager. One or more qualified individuals must provide oversight of all patient care services and personnel. Oversight must include the following:

§484.105(c)(1) Making patient and personnel assignments.

§484.105(c)(2) Coordinating patient care.

§484.105(c)(3) Coordinating referrals.

§484.105(c)(4) Assuring that patient needs are continually assessed.

§484.105(c)(5) Assuring the development, implementation, and updates of the individualized plan of care.



Services (cont. 3)

• §484.105(d) Standard: Parent-branch relationship.

§484.105(d)(1) The parent HHA is responsible for reporting all branch locations of the HHA to the SA at the time of the HHA’s request for initial certification, at each survey, and at the time the parent proposes to add or delete a branch.

§484.105(d)(2) The parent HHA provides direct support and administrative control of its branches.



Services (cont. 4)

• §484.105(f) Standard: Services furnished.

§484.105(f)(1) Skilled nursing services and at least one other therapeutic service (physical therapy, speech-language pathology, or occupational therapy; medical social services; or HH aide services) are made available on a visiting basis, in a place of residence used as a patient’s home. An HHA must provide at least one of the services described in this subsection directly, but may provide the second service and additional services under arrangement with another agency or organization.

§484.105(f)(2) All HHA services must be provided in accordance with current clinical practice guidelines and accepted professional standards of practice.



Services (cont. 5)

• §484.105(g) Standard: Outpatient physical therapy or speech language pathology services. (Moved into this standard; formerly a distinct CoP)

An HHA that furnishes outpatient physical therapy or speech-language pathology services must meet all of the applicable conditions of this part and the additional health and safety requirements set forth in §485.711, §485.713, §485.715, §485.719, §485.723, and §485.727 of this chapter to implement section 1861(p) of the Act.

• §484.105(h) Standard: Institutional planning. (No change)


§484.110—Clinical Records

• Substantial revisions, expanding from two to five standards.

• Greater specificity in regard to the minimum requirements for the content of the clinical record, as well as discharge and transfer summary requirements, in §484.110(a).

• A new standard, Authentication, at §484.110(b).

• Retention of records requirement remains five years in §484.110(c), with additional requirement for clinical record retention after a HHA discontinues operation, and the HHA must inform the SA where the records will be maintained.

• In §484.110(d), protection of records must comply with the Health Insurance Portability and Accountability Act (HIPAA).

• A new standard, Retrieval of Clinical Records, at §484.110(e).


§484.110—Clinical Records (cont.)

• §484.110(a) Standard: Contents of clinical record. The record must include:

(1) The patient’s current comprehensive assessment, including all of the assessments from the most recent HH admission, clinical notes, plans of care, and physician orders.

(2) All interventions, including medication administration, treatments, and services, and responses to those interventions.

(3) Goals in the patient’s plan of care and the patient’s progress toward achieving them.

(4) Contact information for the patient, the patient’s representative (if any), and the patient’s primary caregiver(s).

(5) Contact information for the primary care practitioner or other health care professional who will be responsible for providing care and services to the patient after discharge from the HHA.


§484.110—Clinical Records (cont. 1)

(6) (i) A completed discharge summary that is sent to the primary care practitioner or other health care professional who will be responsible for providing care and services to the patient after discharge from the HHA (if any) within five business days of the patient’s discharge;

or (ii) A completed transfer summary that is sent within two business days of a planned transfer, if the patient’s care will be immediately continued in a health care facility;

or (iii) A completed transfer summary that is sent within two business days of becoming aware of an unplanned transfer, if the patient is still receiving care in a health care facility at the time when the HHA becomes aware of the transfer.



• §484.110(b) Standard: Authentication. All entries must be legible, clear, complete, and appropriately authenticated, dated, and timed. Authentication must include a signature and a title (occupation), or a secured computer entry by a unique identifier, of a primary author who has reviewed and approved the entry.

• §484.110(c) Standard: Retention of records.

(c)(1) Clinical records must be retained for five years after the discharge of the patient, unless state law stipulates a longer period of time.

(c)(2) The HHA’s policies must provide for retention of clinical records even if it discontinues operation. When an HHA discontinues operation, it must inform the state agency where clinical records will be maintained.



• §484.110(d) Standard: Protection of records. The clinical record, its contents, and the information contained therein must be safeguarded against loss or unauthorized use. The HHA must be in compliance with the rules regarding personal health information set out at 45 Code of Federal Regulations (CFR), Parts 160 and 164.

• §484.110(e) Standard: Retrieval of clinical records. A patient’s clinical record (whether hard copy or electronic form) must be made available to a patient, free of charge, upon request at the next home visit, or within four business days (whichever comes first).


§484.40 Release of Patient Identifiable OASIS Information

§484.45 Reporting OASIS Information

• §484.40 Release of patient identifiable

OASIS information. (No change)

• §484.45 Reporting OASIS information.

(Revised encoding and transmitting OASIS

data to the CMS system)


§484.115 Personnel Qualifications

§484.115(a) Standard: Administrator, HHA.

(1)For individuals that began employment with the HHA prior to January 13, 2018, a person who:

(i) Is a licensed physician;

(ii) Is a registered nurse; or

(iii) Has training and experience in health service administration and at least one year of supervisory administrative experience in HH care or a related health care program.


§484.115 Personnel Qualifications (cont.)

(2) For individuals that begin employment with an HHA on or after January 13, 2018, a person who:

(i) Is a licensed physician, a registered nurse, or holds an undergraduate degree; and

(ii) Has experience in health service administration, with at least one year of supervisory or administrative experience in HH care or a related health care program.

•§484.115(c) Standard: Clinical Manager.

A person who is a licensed physician, physical therapist, speech-language pathologist, occupational therapist, audiologist, social worker, or a registered nurse.


Top 10 Survey Deficiencies Home Health


HHA Survey Process


HHA Survey Process

• Frequency defined in Section 1891 of the Social

Security Act and 42 CFR §488.730.

• Each HHA must be surveyed no later than 36

months after the last day of the previous standard

survey.

• Surveys may be conducted as frequently as

necessary to assure delivery of quality care by

determining if an HHA complies with the CoPs and

confirming HHA has correct previously cited

deficiencies.


State Operations Manual (SOM)


SOM Appendix B


CMS QSO Memos


QSO-18-13-HHA Memo


Draft HHA Interpretive Guidance


Standard Survey

• Review Level 1 standards and conditions of

participation.

– Determines quality of care and services furnished by a

HHA.

– Measured by indicators related to medical, nursing and

rehabilitative care.

• Level 1 standards contain process and

administrative standards.

• Deficiencies found in Level 1 have a high likelihood

of effecting care delivery and patient outcomes.


Partial Extended Survey

• Triggered when 1 or more Level 1 standard

deficiencies are found.

• Triggered when survey team suspects additional

problems outside Level 1 standards.

• Expands investigation to include Level 2

standards under the deficient Level 1 standard

CoPs.

• Additional standards may be examined.


Extended Survey

• Triggered by:

– CMS or State Agency (SA).

– Identification of a condition-level deficiency.

• Review: CoPs outside of standard survey,

policies and procedures, practices that may

have produced the substandard care.

• Initiated immediately upon finding

substandard care.


Survey Tasks


Task 1- Presurvey Preparation

• Review Historical Documents

– Form CMS-1572, HHA Survey and Deficiencies

Report

– Form CMS-2567, Statement of Deficiencies and Plan

of Correction

– Complaint Investigations

– OASIS Quality Improvement CASPER Reports• Potentially Avoidable Event Risk Adjusted Report

• Potentially Avoidable Event: Patient Listing Report

• Agency Patient-Related Characteristics (Case Mix) Report


Task 2 - Entrance Conference

• Inform the Agency of the Survey Purpose

– Introduce team and show identification and business

cards

– Speak to the administrator or predesignated person

authorized to serve as the administrator

– Give estimated timeframe

– Explain process (observations, patient and staff

interviews, medical record and document review)

– Inform administrator of the survey type

– Request space to work and a point of contact


Task 3 – Information Gathering

• Sample Selection

– Active and closed records

– Case mixed-patients receiving different services

– Stratified-patients admitted with different primary

diagnoses.

– Home visits ideally include registered nurse (RN),

therapist, and home health aide services.


Sample Size

Courtesy of CMS (Center for Medicare and Medicaid Services)


Task 4 – Information Analysis

• Review all information gathered during the

previous survey process tasks.

• Determine HHA compliance by considering:– Effect on patient care outcomes.

– Degree of severity.

– Frequency of occurrence.

– Impact on delivery of services.


Task 5 and Task 6

• Task 5 - Exit Conference

• Task 6 – Formation of the Statement of

Deficiencies (SOD)


HHA Alternative Sanctions

• Final Rule – November 8, 2012

• Any CoP out must begin an enforcement

case in AEM regardless of sanction

imposition

• SOM Chapter 10


OASIS Education & IDR Coordinator

Buffy Stone, RN, NC/I

RAI/MDS, OASIS, IDR/IIDR Coordinator

Office of Inspector General

Division of Healthcare

Training & Quality Assurance Branch

L&N Building, 10-W

908 W. Broadway

Louisville, KY

Phone: (502) 595-4958 ext: 5019

Fax: (502) 595-4540


Questions