Characteristics Differentiating Branches From Subunits of

2182.1 - Characteristics Differentiating Branches From Subunits of HHAs (Rev. 125, Issued: 10-31-14, Effective: 10-31-14, Implementation: 10-31-14) The comparisons on the following pages identify and clarify policies that assist in making a distinction between a branch and a subunit. The surveyor discusses any discrepancies with the administrator or his/her designee and alerts the SA supervisor who then notifies the CMS RO. Administrative Functions (Relationship with Parent Agency) Branch - Not autonomous. Is part of the HHA and shares administration, supervision and services with the parent agency on a daily basis. The administration at the parent agency is aware of the staffing, patient census and any issues/matters affecting the operation of any given branch. The branch location provides the same services as the parent within a portion of the total geographic area served by the parent agency. Subunit - Semi-autonomous and located at such a distance from the parent agency that it is incapable of sharing administration, supervision, and services on a daily basis. Serves patients in a geographic area different from that of the parent. A subunit may have a branch. Compliance with CoPs Branch - Does not have to independently meet the CoPs as an HHA. Subunit - Independently meets all CoPs as an HHA. Organizational Structure (See §484.14.) Branch - The lines of authority and professional and administrative control are clearly delineated in both organizational structure and in practice and can be traced to the parent agency. Subunit - The lines of authority and professional and administrative control are clearly delineated in both organizational structure and in practice. Supervision (See §484.2.) Branch - Supervision is shared between the parent agency and the branch. However, if the branch is so large (i.e., has a large staff and serves many patients) or is so distant that it is impossible for a supervisor of a specific discipline to accomplish adequate supervision, the branch must convert to a subunit. Subunit – It is too far from the parent agency to share supervision on a daily basis. The subunit functions independently of the parent, and consequently, supervision is provided by staff designated by the subunit. Administrator (See §484.4.) Branch - The administrator of the HHA maintains an ongoing management of the branch staff and liaison with the group of professional personnel. In order to accomplish this activity, sufficient time must be allocated for sharing information with all the parties mentioned. The branch is located sufficiently close to the parent to share administration. The administrator is apprised of and resolves issues affecting patients in branch(es) as well as the service area(s) covered by the parent. Subunit - It is too far from the parent agency to share administration on a daily basis. Is semi-autonomous and maintains its own administrative staff (e.g., supervising physician or registered nurse). It functions as an independent entity. Supervising Physician or RN (See §484.14(d).) Branch - The location of the branch, in relation to the parent, is such that the parent is able to assure adequate supervision during all operating hours. (See §2182.4B) Subunit - Supervisory M.D. or RN is available during all operating hours. Personnel Policies (See §484.14(e).) Branch - The parent office maintains current personnel records on all staff. A statement of personnel policies is maintained in each branch for staff usage. Subunit - Personnel policies and records must be maintained at the subunit. Coordination of Patient Services (See §484.14(g).) Branch - Information concerning care provided to patients is communicated to staff in branches and parent agency, particularly when staff of one organizational unit (e.g., branch) does not base its practice at that site. (Example: A physical therapist (PT) provides services to patients managed by the parent agency as well as patients managed by the branch. Most of the PT’s time is spent with patients from the branch, although occasionally a patient followed by the parent agency is included in his/her workload. The PT is expected to coordinate care with staff in each organizational unit [i.e., branch or parent] as required by the patient’s needs and as practice dictates.) Subunit - Since the subunit is a semi-autonomous entity, coordination is simplified because staff is generally available on a regular basis or can easily be reached to discuss and implement the coordination of patient care. Services Under Arrangements (See §484.14(h).) Branch - Contracted arrangements with various entities are the responsibility of the parent agency, even when the contracted services are used exclusively by the branch. Subunit - Maintains contracts with various entities to provide services. The subunit is responsible for the administration and supervision of those services. Parent agency monitors subunit services provided under arrangements. Group of Professional Personnel (See §484.16.) Branch - The annual review of the agency’s policies is conducted by a group of professional personnel. Their focus is directed on service delivery throughout the entire agency including the parent agency and branch(es). Subunit – The subunit may establish its own group of professional personnel or it may form a subcommittee of the parent HHA’s group which deals specifically with the subunit’s policies and procedures at that subunit. The parent agency and subunit’s policy statements and minutes of group meetings must include specific references to issues addressed in the delivery of home health services. Clinical Records (See §484.48.) Branch - Should retain the clinical records for its patients, since the branch site is where the professionals providing the services are located. Duplicate records need not be maintained at the parent agency, but must be made available to the surveyor upon request. Subunit - Maintains clinical records on all its patients.