NR 510 Week 4 Clinic Policy Influence Plan Example

Policy Influence Plan: Getting One Sentence About Home Health Certification Into the Clinic's Patient Care Policies at the January Meeting of the Group Federal Rules Require, With the Medical Director as Sponsor

Student Name

College of Nursing, Chamberlain University

NR 510: Leadership and Role of the APN

Instructor Name

Month Day, Year

Policy Influence Plan: Getting One Sentence About Home Health Certification Into the Clinic's Patient Care Policies at the January Meeting of the Group Federal Rules Require, With the Medical Director as Sponsor

Aim at Whoever Holds the Instrument

My Week 3 brief found that our nurse practitioner's inability to start home health care is not caused by federal or state law, but by a home health agency's outdated form and by our own clinic's EHR permissions. Behind both sits a gap in our clinic's written patient care policies, which say nothing about who may certify home health eligibility. The agency and the EHR are easier to change once the clinic's own policy states the answer, so the policy is the instrument this plan targets.

The body that holds it is specific. As a certified rural health clinic, our clinic must have written patient care policies developed with the advice of a group of professional personnel that includes one or more physicians and one or more physician assistants or nurse practitioners, with at least one member who is not on the clinic's staff, and the policies must be reviewed at least every two years by that group (Patient Care Policies, 2024). At our clinic, this group is called the Policy Review Committee. Its members are the Medical Director, the physician assistant, the nurse practitioner, the office manager as secretary, and an outside member, a retired family physician from the next county. It, not the legislature or the owners' meeting, can adopt the sentence this plan needs.

The Calendar Is a Constraint

The committee meets quarterly, on the second Tuesday of January, April, July and October. Items for the agenda close two weeks before the meeting, and proposals must be submitted to the office manager as a redlined copy of the existing policy with a half-page rationale. The last full biennial review was in October 2025, so the next is due in October 2027, but any policy can be amended at any quarterly meeting.

That calendar sets the plan's dates. The October 2026 meeting has passed. The next opportunity is January 12, 2027, with items due by December 29, 2026. If the proposal misses that meeting, the next is April 13, three more months in which patients wait for a physician's signature.

One Sentence, Written for Them

The committee votes on text, not on awareness, so the proposal is a single sentence to be added to the section of the policy titled "Referrals and Arrangements for Services Not Furnished Directly":

"A physician, nurse practitioner or physician assistant who has performed and documented the required face-to-face encounter may certify a patient's eligibility for Medicare home health services, as permitted by 42 C.F.R. § 424.22, and may complete the home health agency's referral."

The rationale, half a page, will quote the current federal regulation, which allows a physician or allowed practitioner to certify eligibility (Requirements for Home Health Services, 2024), and the definition that includes nurse practitioners and physician assistants among allowed practitioners (Home Health Services Definitions, 2024). It will add the six-day delay experienced by the patient described in Week 3 and the office manager's count of how many home health referrals required a physician co-signature in the past quarter.

Find a Sponsor Early

A proposal from the newest member of a committee, about the proposer's own authority, is easy to table politely. The Medical Director is the right sponsor. He chairs the committee, he signs the co-signatures that the current practice requires and would lose time to under the old arrangement, and he is responsible under federal rules for the clinic's medical direction. I will ask him in November, in a scheduled 15-minute meeting, to review the sentence and to put it on the January agenda under his name, with me presenting the rationale.

The outside member deserves a separate conversation. As a retired physician from another county, he may not know that the federal rule changed in 2020. A short email with the regulation text in December, before the meeting, avoids surprising him in the room.

The Objection to Expect

The most likely objection in the room is not about law but about liability: if the NP certifies a patient who turns out not to be homebound, who answers for it when Medicare reviews the claim? The rationale should answer that before it is asked. The regulation places the responsibility on whoever certifies, and it requires the certifying practitioner's documentation to support eligibility. The sentence therefore ties certification to the practitioner who performed and documented the face-to-face encounter, so the person certifying is the person who saw the patient. The Medical Director's periodic review of records, which the clinic already performs under federal rules, can include a sample of home health certifications in its first year, which gives the committee a way to check the change without delaying it.

What Happens After the Vote

Adoption of the sentence is the first step, not the last. Within a week of the meeting, the office manager will ask the EHR vendor to open the home health referral order to the nurse practitioner and physician assistant accounts, citing the adopted policy. The Medical Director will write to the person who runs intake and clinical operations at the home health agency, enclosing the policy and the regulation text, and asking that the agency's referral form be revised to read "Ordering physician or allowed practitioner."

Say What Counts as Movement

Progress is defined in advance, so the plan can be judged honestly:

By December 29, 2026: the proposal submitted to the office manager, sponsored by the Medical Director.

January 12, 2027: the committee votes. Adoption, with or without wording changes, counts as success. Tabling to April counts as partial movement if the committee names what it needs to see.

By January 31, 2027: EHR permissions changed.

By March 31, 2027: the agency's form revised, or a written reply from the agency explaining why not.

By June 30, 2027: the median time from NP visit to first home health visit, tracked by the office manager, falls from the current four to six days to two days or fewer.

If the committee rejects the sentence, the plan does not escalate to external advocacy, because no law stands in the way. Instead, I will ask the Medical Director what change to the wording would make it acceptable, and bring a revised version to April.

References

Home Health Services Definitions, 42 C.F.R. § 484.2 (2024). https://www.law.cornell.edu/cfr/text/42/484.2

Patient Care Policies, 42 C.F.R. § 491.9 (2024). https://www.law.cornell.edu/cfr/text/42/491.9

Requirements for Home Health Services, 42 C.F.R. § 424.22 (2024). https://www.law.cornell.edu/cfr/text/42/424.22