Hospice Conditions of Participation

1. Hospice Conditions of Participation Presented by Kim Roche, RN, BSN, RNC, CCS-P CMSO/SCG The Centers for Medicare & Medicare Services January 22, 2009

2. Medicare Hospice Conditions of Participation • Published May 27, 2008 • Effective December 2, 2008 • Performance Improvement Projects begin 02/02/09

3. www.cms.hhs.gov/center/hospice.asp

4. Secretary’s Advisory Committee on Regulatory Reform • Clarified relationship between NHs, ICF/MRs and hospices • Changed respite care nursing requirements • Allowed qualified nurses to provide dietary counseling

5. BBA ’97 changes • Medical director/physicians may be under contract (§418.64 and §418.102) • Waiver available to provide PT, OT, SLP, and dietary counseling on 24-hour basis (§418.74 )

6. BBA ’97 changes (Con’t) • Waiver available for providing dietary counseling directly (§418.74)

7. MMA ‘2003 • Hospices may contract with another hospice to provide core hospice services • Hospices may contract with RN for highly specialized services

8. Hospice’s Responsibility • Inform Patients of Rights in Language they understand • Report Violations to Administrator & State • Investigate Violations • Obtain Patient’s Signature • Comply with Advance Directives

9. Patient’s Rights Effective Pain Medication Respect for Property & Person Choose Attending Confidential Clinical Records Symptom Management Voice Grievances without reprisal

10. Patient’s Rights (Con’t) Exercise Rights Refuse Care or Treatment Receive information about hospice Freedom from Mistreatment, Neglect/ abuse Involvement with Care

11. Registered Nurse Completes within 48 hours of effective date of election Patient or Physician may request earlier assessment. Gathers key information to treat patient Initial Assessment

12. Comprehensive Assessment

13. Comprehensive Assessment (Con’t)

14. Assessment Timeframes (example)

15. IDG Meets Physical, Medical, Psychosocial, Emotional, and Spiritual Needs of Pt/family Includes MD or DO, SW, RN Counselor Provides Education/ Training to Pt/Family Consults with Attending Physician

16. Plan of Care

17. Plan of Care (Con’t)

18. Performance improvement activities • Focus on high risk, high volume, or problem-prone areas • Track adverse patient events & analyze causes • Affect palliative outcomes, patient safety, and quality of care

19. Performance Improvement Activities (Con’t) • Consider incidence, prevalence, and severity of problems • Take actions aimed at PI & measure success • Track PI actions to assure improvements are sustained

20. Performance Improvement Projects • Starts February 2, 2009 • Reflect scope, complexity & past performance of hospice’s services & operations.

21. Performance Improvement Projects (Con’t) • Document the quality improvement projects conducted • Document reasons for conducting the projects and measurable progress achieved

22. Infection Control • Accepted standards of practice • Prevents and Controls Infections & Diseases • Part of QAPI • Educates/Protects, Patients, Staff and others

23. Infection Control • Agency wide program for surveillance, identification, prevention, control and investigation • Identifies Infectious and Communicable Diseases and Implements Appropriate Actions

24. Licensed Professional Services • Services must be authorized, delivered, and supervised by qualified personnel • Professionals participate in coordinating all patient care • Professionals participate in the hospice’s QAPI and in-service training programs

25. Hospice Core Services • Physician Services (direct or under contract) • Nursing Services • Medical Social Services

26. Hospice Core Services (Con’t) • Counseling Services • Bereavement • Dietary • Spiritual

27. Hospice Aide Qualifications • Training & competency evaluation OR • Competency evaluation OR • Nurse aide training and competency evaluation OR • State licensure program

28. Hospice Aide Supervision • RN supervises aide onsite once annually if no problems noted. • RN visits patient q. 14 days to assess aide services (aide does not have to be present) • If concerns, RN revisits to observe aide • If concerns remain, aide completes competency evaluation

29. Volunteer Hours Level of ActivityExample

30. Recruit, Train, & Supervise • Hospice must: • Document active volunteer recruitment • Document retention plans • Provide orientation & training for its volunteers—consistent with hospice industry standards • Volunteer program must be supervised by a designated hospice employee