Home Health & Hospice Week

Tip: A single checkmark won’t do the job.

How extensive your aide supervisory visit documentation should be may depend on how much risk you are willing to bear in exchange for less burden.

The “regulatory language regarding the supervision of hospice aides does not explicitly state how the registered nurse must document his/her supervision of the hospice aide,” points out Carrie Cooley with Weatherbee Resources in Headland, Alabama. That “lack of regulatory specificity regarding the documentation of hospice aide supervisory visits by the RN may be partly responsible for some of the hospice industry’s noncompliance,” as shown in the latest HHS Office of Inspector General report, Cooley observes.

That also makes it a tougher job to figure out exactly how to ensure compliance. “How each hospice decides to document its supervisory visits may depend on a number of factors, including that hospice’s aversion to risk, the time it wants to devote to documenting supervisory visits, and how it uses that documentation to improve the performance of hospice aides,” says attorney Brian Nowicki with Reinhart Boerner Van Deuren in Madison, Wisconsin.

The OIG and hospice experts agree that a single checkmark just indicating a supervisory visit occurred is not enough to comply with the condition of participation requirement for an aide supervisory assessment. Technically, “there is no prohibition on using checkboxes and there is no requirement to use detailed record entries,” Nowicki acknowledges. But “substantive requirements for documenting supervisory visits” make a single checkmark or even brief entry insufficient, he notes.

That doesn’t mean you can’t make your supervisory visits more efficient with some checkboxes, offers Robert Markette Jr. with Hall Render in Indianapolis. A “supervisory visit note” form could “note the date of the visit, who performed the visit, which aide was supervised, and the aide’s performance,” Markette offers. Then the form could “use a series of checkboxes” based on the points noted in the regulation: “followed the POC, followed infection control, etc.,” Markette continues. Then spaces for narrative could address any concerns, follow-up needed including aide education, and information the patient provides, Markette says.

Watch out: While a list of checkboxes could be efficient and address compliance, “there are drawbacks,” Nowicki cautions. Using a list of checkboxes only “may result in greater scrutiny and additional questions concerning supervisory visits. Checkboxes also do not lend themselves to the customized skills and performance assessment, specific to each hospice aide, that the regulations appear to anticipate,” Nowicki tells Eli.

Mix it up: On the other hand, “a detailed record entry … avoids these limitations of the checkbox format, but can be time consuming,” Nowicki concedes. “A hybrid approach, where there are checkboxes but also additional space to include specific notes when warranted,” may be a good compromise.