Eli's Hospice Insider

Published on Wed Oct 16, 2013 PDF

Most common hospice deficiencies can help nursing homes prepare for surveys.

Under new requirements, nursing facilities must designate an individual — a clinical member of the interdisciplinary team — as the point person for coordinating and communicating with a hospice. This person will collaborate on care planning and be responsible for ensuring adequate communication.

Facilities trying to bolster their survey defenses when contracting with you should consider the Centers for Medicare & Medicaid Services’ 2012 list of the 10 most common hospice deficiencies:

L543 – §418.56(b) Standard: Plan of care
L629 – §418.76(h) Standard: Supervision of hospice aides
L545 – §418.56(c) Standard: Content of the plan of care
L530 – §418.54(c)(6) – Drug profile
L555 – §418.56(e)(2) – Ensure that the care and services are provided in accordance with the plan of care
L591 – §418.64(b) Standard: Nursing services
L552 – §418.56(d) Standard: Review of the plan of care
L596 – §418.64(d) – Counseling services
L615 – §418.76(c) Standard: Competency evaluation
L523 – §418.54(b) Standard: Timeframe for completion of the comprehensive assessment

Can’t-miss resource: With those trouble spots in mind, advise SNFs to review CMS surveyor guidance available at: www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-13-44.pdf. 

Beware These Potential F-Tags

For nursing facilities, the F-tag of top concern will be F-309 (Quality of Care). CMS’s latest interpretative guidance is available at

www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-12-48.pdf.

Another F-tag likely to remain in play in assessing the care of residents receiving hospice is F353 (Sufficient Staff). Current guidance tells surveyors to determine whether the facility had qualified nursing staff in sufficient numbers to assure the resident was provided necessary care and services 24 hours a day, based upon the comprehensive assessment and care plan.

Depending on the level of hospice care provided, this could mean 24-hour on-site care by a registered nurse, with documentation of skilled care at the general inpatient (GIP) level.

Tip: Although the responsibility is not among those noted in the final rule, experts are advising facilities to inform residents electing hospice of the potential effect on their out-of-pocket expenses, says Terry Berthelot, senior attorney with the Center for Medicare Advocacy. You may want to work with your SNF partners to make sure the information they disseminate is accurate, experts suggest.