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Home Health & Hospice Week

Hospice:

UPCOMING REG MAY CUT HOSPICE-SNF CONFUSION

Published on Thu Jul 22, 2004

COPs, amendments also on hospice horizon.

A condition of participation on how long-term care facilities must handle hospice services is in the works, and the result could be better relationships between the two types of providers.

The Centers for Medicare & Medicaid Services proposes a LTC facility COP on hospice "to ensure that quality hospice" is available to nursing home residents, the agency says in its most recent Semiannual Regulatory Agenda in the June 28 Federal Register.

Janet Neigh of the Hospice Association of America cheers the move, noting it "will give clear guidance on hospice to skilled nursing facilities for the first time." The COP will lay out how facilities and hospices should divide responsibilities for aide services, among other items.

The guidance will make clear that there must be one plan of care for a nursing home resident under the hospice benefit, and the hospice must be in charge of it, Neigh expects. Hospices already have received guidance on SNF-hospice relationships, including a best practices compilation, in the state operations manual, Neigh tells Eli.

"Surveys of SNFs with hospice standards should be a good thing since SNFs focus on rehab and hospice focuses on comfort care," comments Linda Rutman, director of Munson Home Care and Home Services in Traverse City, MI. "Some SNFs do a better job than others at supporting the hospice mission and goals for patient care."

Good coordination requires additional oversight and education of the SNF by the hospice, Rutman says. SNFs must learn to identify and address patient care needs through the hospice interdisciplinary team plan.

CMS bumped back the COP's publication date from September of this year to January 2005, according to the agenda. Other hospice items in the agenda include:

  • Hospice COPs. It's no surprise that CMS has pushed back publication of the hospice conditions of participation, since it's been doing so for years now, Neigh notes. This time CMS pegs their release at next May.

    But a CMS official has told the National Association forHome Care & Hospice the home health agency and hospice COPs are likely to come out earlier than the agenda's target date (see Eli's HCW, Vol. XIII, No. 25).

  • Amendments. Other candidates for long delays are a number of hospice amendments dating back to Medicare laws from 1997 (BBA), 1999 (BIPA) and 2000 (BIPA), notes Judi Lund-Person with the National Hospice and Palliative Care Organization. The amendments have largely been implemented already through program memoranda and other directives, Lund-Person says.

    CMS has set a date of November 2005 for a final rule on the amendments, which were proposed back in November 2002 (see Eli's HCW, Vol. XI, No. 43).

  • Fire safety. You can expect a final rule on the 2000 Life Safety Code fire safety standards in May of next year. The standards will apply to inpatient hospices and Program of All-inclusive Care for the Elderly (PACE) providers, among other facilities.

  • Wage index. As usual, the annual update to the hospice wage index is expected in August. Hospices shouldn't expect the 2003 Metropolitan Statistical Area (MSA) changes to go into effect until next time around, taking effect for 2006 payment rates, Lund-Person says.

    Editor's Note: The agenda is at www.access.gpo.gov/su_docs/fedreg/a040628c.html.

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