Monday, February 9, 2009
(This is the fourth in a series of 5 posts (#5, #4, #3) about issues in hospice & palliative medicine I think will be important in the next year. Feel free to disagree!)*
#2 Making Sense of the new Medicare Hospice Conditions of Participation
We have not covered a ton of the bureaucratic and administrative sides of hospice or palliative medicine here at Pallimed. I would recommend the Hospice Blog by Hospice Guy for a sharper focus on such topics (all Hospice Blog COP related posts here). The Conditions of Participation (COP) for the Medicare Hospice Benefit is basically a rule book for how hospices must operate since all hospice derive a majority of their revenue from Medicare. The new COPs went into effect on December 2nd and hospices are trying to best interpret all of the subtle and drastic rule changes that were made.
Thankfully, Medicare did have a period for input from hospice agencies and other advocate groups before publishing the final COPs. It is interesting how many conferences, software programs, and seminars have cropped up to help indicate what kind of demand there is to KNOW that your agency is compliant with the regulations.
Some key quotes from Hospice Guy:
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.Make sure to read his COP related posts comments from other hospice administrators if this is a topic you are interested in. And contribute if you have a particular view or insight on the COP's
I do think some of the changes are going to be very hard on small hospices and somewhere near impossible for small rural hospices that cover hundreds of miles of territory. I'm not sure that the provision that each patient must be seen by a nurse, social worker, and chaplain within four calendar days of admission is possible or practical for some of those small rural hospices.
As the new COPs are implemented it will be interesting to see what unintended consequences shake out of the process. Will referring doctors be frustrated by a possible increase amount of paperwork or contact in an effort to better document collaboration with a primary doctor? Will new processes put in place to meet compliance standards result in less time, money and effort directed towards patient care for 'non-essential' (or essential) programs? What will be interpreted as a hard and fast law instead of a guideline as the original authors may have intended?
Time will tell. (Sorry about the cliche. It's getting late!)