hospice conditions of participation

Wednesday, June 04, 2008

Hospice Conditions of Participation Workshop

This is not the first time where my membership in NHPCO has made it hard to know what I should or should not say on this blog. In theory, everything that I know to date about the new Medicare Hospice Conditions of Participation is from publically accessible information. In reality, there is no way that I would know everything that I know without the help of the National Hospice and Palliative Care Association. NHPCO has done a great job of getting insight and information out to its membership about the new COP’s. They are in the middle of a two day workshop in Baltimore that is being webcast at no charge to NHPCO members. While the subject matter is dry, it is somewhat amazing to get to hear the people from CMS who actually drafted these rules talk about them. There are two women from CMS presenting, and they clearly know this subject well. In the introduction I believe they said one of them had been working on this project for ten years. Having the opportunity to hear those people tell us what they intended when they wrote these regulations has really helped me understand the intent behind the new regs.

With all of that said, I have chosen not to discuss specific regulations on this blog for a few weeks. It is my understanding that there are representatives from each state in the union attending this conference that is being webcast who were invited to learn this material and then teach it to their states. With that in mind, I don’t want anyone to confuse this blog for a place to go to learn the regulations. Even if I started a discussion about some of the specific regulations, there is no way we could cover everything. When you see your state association or some other group offering the seminar that they are preparing for in Baltimore, you need to go. In fact, a bunch of people from your hospice need to go! There is a lot of information here, and the changes are not going to be easy. We, as a hospice industry have our work cut out, and you need to get your organization in the game if it isn’t already.

Between these new regulations, the new billing requirements, the proposed hospice rate cuts, and the possibility of major changes in our payment system on the horizon, I really encourage those of you who are still trying to do hospice in a bubble to come on out and join the rest of the movement. NHPCO is working very hard to keep the industry safe, and they could really use your dues. You could also use their help! I promise you, you are going to be needing help over the next 6-9 months!

No, I do not work for NHPCO. Actually, if you review this blog’s history, you’ll probably find that I have not always been a fan of NHPCO, but we are well past the time where hospices can try to go it alone. We need to speak with one voice, and NHPCO has worked very hard to be that voice for all of us.



Don’t worry, if they read your post from May 26, they won’t have ANY chance of thinking this is the place to learn regs. Specifically this part:

“….The person you are talking to on the phone knows exactly how far they can push that envelope to offer things that are above and beyond the norm. If you ask them for something that is beyond the company norm during that initial phone conversation, they might say yes. If you ask for that a month after you sign up, it will be much easier to tell you that hospice doesn’t usually do that kind of thing. Once you have signed on and built relationships with the hospice staff, the hospice will assume that you are not going to leave for another hospice over something minor. If you ask for it before choosing a hospice, they know it could be a make or break detail. If you are going to sign yourself or a loved one up for hospice, make sure you ask your questions and get your promises up front.”

From what I heard on Wednesday you will need to educate the people you serve with a list of all services. There will be no picking and choosing what you can offer people just so you can get them signed on. It’s either included or it isn’t. It shouldn’t be dependant on when they sign on. That is low.

Hospice Guy

I really get tired of these types of cheap shots. Anyone who wants to see the context of and a discussion about the quote in anonymous’ comment, please see the original post.

On the subject, anonymous, I also heard that, and am very happy to hear it. That will clear many things up! Unfortunately, I also heard them say that a hospice was not required to provide everything the family requests. The exact example they used was, -if you assess that the patient needs an aide three times a week and the family requests five times a week, you are not required to provide the aide the extra two times.- Now I think that is crap, but it is apparently legal. I get very tired of people who work in hospice acting like the Medicare Hospice Benefit is this static thing that never involves judgement.