I hope you've become familiar with the proposed federal rules for home care prospective payment (PPS) that were published in the Federal Register on October 28, 1999. As in all published rules, there was a comment period, in this instance, 60 days, which happened to include the holiday season. Because final comments were due in HCFA's office on December 27, 1999, I thought of making a request to Santa to drop them off in Baltimore to expedite the process and to thank the government for such a sweet present.

The last issues of HHN and HHNManager presented insightful comments from home care experts throughout the country on the anticipated changes ahead for the home care industry and the practice of home care and hospice nursing. This month, HHN has several articles that examine how IPS, PPS, and other legislation impacts your practice and your patients. Understanding how these major legislative and regulatory changes affect you is as important as learning updates in disease and medication management.

Reading all the regulations (75 Federal Register pages) was not an easy task for anyone and I commend the many individuals, home care organizations, companies, and state and national associations who sent written comments to HCFA. If you haven't looked at the regulations, at least read the summaries that I am hopeful are in your agency; perhaps you've shared them in a staff meeting.

As I read the regulations and the many comments posted on listervs, and talked to numerous providers, several things became clear:

1. Implementing a home care PPS by October 1, 2000 is going to be a major change for everyone in home care-especially because the final rules won't be published until July 1, 2000 (yes, that gives us only 3 months to implement them!)

2. Numerous items in the proposed regulations need reexamination and change before HCFA's goal of having a system that is feasible, clinically logical, valid, and accurate can be achieved.

3. The current cost-based Medicare reimbursement system encourages clinicians' to deliver care first considering Medicare regulations. PPS will demand that clinical expertise and judgments are used to assess and plan care based on outcomes.

4. Although we are currently experiencing the beginnings of a nursing shortage with more dire predictions coming for the next decade, we need to find and keep the best clinicians in home care. The PPS system is clinically driven with the focus on determining the volume and type of home care services each individual patient requires. Only expert clinicians will be able to make those decisions.

5. Research, evidence-based practice, and data will drive the care provided in the new system. It is not enough to say we deliver good care or provide high quality-it must be backed up with data.

Although we may be fearful of this new system, it does provide us with a major opportunity. PPS can give us the freedom to deliver the care that is needed in a creative way that challenges us. I agree with the concept and applaud HCFA's intention to let us do what we do best-home care.

The time is now for clinicians to rise to the challenge of determining and evaluating the type and amount of care patients need and receive. We must continue to critique the regulations and be willing to test proposed methods as well as devise new ones to make the PPS system effective.

It requires a great amount of work on our behalf. But we can do it. After all, isn't this what we've been saying we wanted all along?