Home Health & Hospice Week

Do you want professionals other than RNs surveying your agency?

The surveyor-hospice relationship can be a rocky one. Hospices are asking Medicare to make sure their surveyors are up for the job.

Background: The Centers for Medicare & Medicaid Services proposes a bevy of survey-related changes in the home health 2022 proposed rule published in the July 7 Federal Register. Those include “the use of multidisciplinary survey teams when the survey team comprises more than one surveyor, with at least one person being a RN.”

Commenters on the rule generally are supportive of this change. The National Hospice and Palliative Care Organization “enthusiastically support[s] the use of multidisciplinary teams,” NHPCO’s Edo Banach says in the trade group’s comment letter.

“This is a positive step that will increase the likelihood that survey results will include a comprehensive evaluation of the integrated nature of the [interdisciplinary group] and take into account the unique role that various professions play in the provision of the Medicare hospice benefit,” praises the National Partnership for Healthcare and Hospice Innovation in its comment letter.

“Diverse professional backgrounds among surveyors reflect the professional disciplines responsible for providing hospice care as represented in the hospice core services requirement,” says accrediting organization Accreditation Commission for Health Care in its comment letter.

“We appreciate CMS’ call ... for diverse professional backgrounds among surveyors to reflect the professional disciplines responsible for providing hospice care, and its recognition of the disciplines included in the hospice core services requirement,” National Association for Home Care & Hospice executives say in NAHC’s comment letter.

While this proposal enjoys wide support, commenters have plenty of ideas on how to make it better.

Many commenters wanted to know if two-person teams would be allowed to have two RNs serve as surveyors. (One RN is required.) “CMS’ language indicating that survey entities ‘should’ leaves some lack of clarity and promotes confusion about CMS intent,” indicates the National Coalition for Hospice and Palliative Care in its comment letter.

Many providers and their reps are pro-multidisciplinary teams. “We strongly support use of multidisciplinary teams when more than one surveyor is utilized for a hospice survey,” the Coalition stresses.

Others are supportive as long as CMS takes certain precautions. “If an additional discipline is required, we would recommend that individual to be someone who has experience and background providing at least one of the hospice required core services,” suggests LHC Group Inc. CEO Keith Myers in the Lafayette, Louisiana-based chain’s comment letter.

In fact, CMS should “require that all SA and AO surveyors have a background in hospice, or minimally, a background in providing or managing services in a home care setting such as home health services,” Myers urges.

Other commenters agree. “Given that CMS is encouraging the usage of multiple disciplines among survey teams, CMS should also require that these individuals be demonstrably knowledgeable about the hospice COPs and end-of-life care more broadly,” NPHI tells CMS. “However constituted, a survey team should collectively understand the full background and concept of the hospice IDG, including the social work, bereavement, and volunteer-related aspects of the benefit.”

Plus: Medicare may even want to add another category of individuals to survey teams. “We suggest that CMS consider the inclusion of a former hospice administrator or quality improvement professional as an additional discipline to potentially be included by an SA or AO team,” NPHI offers. “A former administrator would bring a perspective and breadth of knowledge to the survey team that cannot be found in other clinically focused disciplines.”

AOs Nope Multidisciplinary Teams

In contrast, the AOs are against the requirement to use multidisciplinary teams. “The Joint Commission strongly supports the use of two RNs when more than one surveyor is needed,” according to its comment letter. “An RN is best suited to perform hospice surveys, as most hospice CoPs relate to the care provided by nursing staff and staff qualifications. Non-RN survey members would be focused on only a narrow set of CoPs, limiting their contributions to multi-member teams,” says The Joint Commission’s Margaret VanAmringe in the letter.

“It is the professional with hospice experience that is key to a valid survey,” says CHAP CEO Nathan DeGodt in the AO’s comment letter. “If more team members are needed for a survey, CHAP adds hospice RNs.” That’s because “as a matter of efficiency and effectiveness, hospice RNs have the practice knowledge and experience to assess physical palliative patient care, as well as understand the role and benefit of psychosocial intervention,” DeGodt explains.

“Hospice nurses have participated in hundreds of interdis­ciplinary team reviews of patient/family need, recommending physical and psychosocial intervention, and assessing patient/ family outcomes. These meetings include utilizing appropriate intervention by chaplains, counselors, and social workers,” DeGodt continues. “CHAP does not support the proposed required addition of chaplains or social workers or other disciplines to survey teams.” That’s because “not all social workers, chaplains or physicians are trained or have experience in palliative care or patient/family intervention prior to death or bereavement.”

In any case, most Joint Commission surveys are conducted by single RN surveyors, VanAmringe points out.

“There are numerous times that it is not necessary to send multiple surveyors on a survey; but rather the number of days on site for one surveyor may instead increase,” ACHC agrees. “We believe that the intent of the rule allows for two surveyors to both be RNs,” the AO adds.

Hospices will find out who CMS has listened to when the agency issues its final rule later this month or early next month.