hospice cops is your hospice compliant

Sunday, December 28, 2008

Hospice COPs – is your hospice compliant?

I’ve been going over my checklists for compliance for my hospice’s implementation of the new Medicare Hospice Conditions of Participation for the thousandth time, and was wondering how many hospices across the nation are not 100% compliant at this point.

The new COPs went into effect on December 2nd, and my hospice was not ready. We’re nearing a month later, and my hospice is still not 100% compliant. Where are those nursing home and and DME contracts we mailed out? How many layers of bureaucracy can any one contract have to go through before someone can sign it?

I’m guessing that I’m not near alone. There are regulations in the new COPs that are hard to accomplish (especially for small hospices). There are also some that nobody seems to fully understand. I don’t think Medicare even understands what they want us to do for some of them. I have spent the last six months putting things in place, but have been dragging my feet on a couple of issues hoping that Medicare would clarify what, exactly, they want us to do. Those clarifications have not come. Clearly, we can’t wait forever. My waiting game has made my hospice knowingly non-compliant for the first time ever. Nothing big. Nothing that effects patient care. Just details that are not totally in place.

How about you?

10
comments:

Christian Sinclair, MD
said…

Thanks for posting on the COP’s I would love to hear a dialogue on implementing of the COP’s. Luckily I am only assoc med dir so I have not had to deal with implementing a lot of the COP’s just doing as I am told when I get the info. Hope to see more comments posted here.

RDeWald
said…

We’re haven’t covered all the bases either. Since we don’t regulate nursing homes there are a couple of things I don’t know how we’re going to do, we haven’t really decided what “comprehensive” means with regard to assessments and we are still in early tweak on our clinical indicators.

~200 ADC non-profit in NYC.


Anonymous
said…

My theory, when it comes to contracts, is that they all have been outsourced to Afganistan, and the mail is very slow there, and you can’t fly an airplane over it, so you have to take the contracts to the lawyers on donkeys. When the lawyers get them, they have to be translated into Afgani, and compared with Sharia law, and then smuggled out wrapped in oriental rugs, which are then diverted at the port and searched for illegal drugs. This takes some time.

RDeWald
said…

As AssocHMD the weirdest thing you are going to have to get used it, in my humble opinion, is that nurses can no longer take orders from associates of the attending. Only the attending and HMD’s can issue orders now.

So, if a nurse needs something and the attending is playing golf, the HMD is on the hook for coverage.


Anonymous
said…

Yes, I’ve been checking my list…twice – three – oh a thousand times! We are not completely compliant, AND we are implementing a new commercial software program and all new hardware at the same time!! We love a good challenge.
NFP – Rural


Anonymous
said…

Same here. We’re extremely upset about this situation.

Has anyone found a set of clinical forms and paperwork that is compliant with the new COPs?

We are using the Briggs set and, while it is compliant, the set for the Comprehensive Assessment is 21 pages long! We have nurses threatening to quit not only us but hospice in general!


Anonymous
said…

is your whole team helping with compliance of the new cops, or is just your administration doing this. also are you expanding or downsizing with the changes.

Suzanne Rosenberg
said…

I’m just looking at it as a journey – there is no way we could implement all of these requirements right way – too many changes in too little time. We are on point of service and I’ve rewritten the visit notes, created an electronic process for creating comprehensive assessments, and the nurse are completely overwhelmed! It’s hard enough getting the day to day work done without changing processes. So I’m just hanging on and trying to enjoy the ride!

Christian Sinclair, MD
said…

Well at least we dont have to worry about implementing ICD-10 until 2013!


theforprofithospiceguy
said…

Our hospice is going through state survey very soon, kinda nerve racking. We have been able to meet almost all of the COP’s with some third party help. As for the contracts, I have not found a magical solution to getting those returned, I have about 30% as of now. I am hoping to show intent and proper diligence as I don’t have any control over the facilities we sent them to.
We were lucky enough to find a third party vendor called Consolo Services that has a very intuitive platform for users that also satisfies many of the COP requirements for us. Someone was asking about comprehensive assesments and long paper forms, this program eliminates those as well as tracking data for QAPI purposes, I strongly reccomend it.
We are implementing our program at the administrative level due to complexities and subsequently farming tasks to individuals and committees once we create a way to track their efforts and have setup thorough processes for them to follow.
We have also created a spreadsheet for our office nurses that tracks a myriad of items ranging from recert dates to to pharmacy used to 24 hr pain assessment. It is almost fully automated (basic input is required) and is always displayed on a large TV screen for visibility, almost like an airline terminal. This allows staff to look at all pertinant information at a glance as well as serving as a reminder to the office nurse as to many COP timelines allowing her to better manage operations. The spreadsheet also pulls data from the tracking sheet and monitors real time performance to be used in QAPI projects. I would be glad to share this if an interest is shown here.
I would like to hear how others are approaching compliance.