The National Association for Home Care & Hospice (NAHC) continues to pursue discussions with CMS regarding their position on not permitting agencies to use pseudo patients for HCA competency evaluations. We know this is particularly difficult with competency evaluations for tub bathing and shampooing. 

It would be extremely beneficial to share some data with CMS about the issues this is causing for providers and beneficiaries.

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* 1. How many home care aides (HCAs) working in your agency have been competency evaluated on an actual patient for all the skills in the revised Conditions of Participation (CoPs) that require the competency evaluation be conducted on an actual patient, including tub bathing and tub shampooing?

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* 2. How many patients do you have on service today on which a HCA can be evaluated in all of the  skills that require an actual patient for the competency evaluation in the revised CoPs, including tub bathing and tub shampooing?

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* 3. How has the recent change requiring that HCA competency skills be evaluated on an actual patient, rather than a pseudo patient, affected your agency?

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