Hospice Advisors Case Study
We would like to share something from the NHPCO communities discussion written by Jennifer Kennedy, Director, Regulatory and Compliance NHPCO…
Jul 17, 2015 9:53 AM Jennifer Kennedy
Hello from NHPCO Regulatory – This post is in follow up to our earlier response regarding the use of after-hours on call services. As previously stated, the federal hospice Conditions of Participation (COPS) indicate that hospices must routinely provide substantially all core services, including nursing services, directly by hospice employees. Such nursing services are not specifically defined, but they are generally discussed in the hospice regulatory context as including patient assessments, care planning and updates to the plan of care, and in-person visits (42 C.F.R. §§ 418.54, 418.56, 418.64). Based on this regulatory framework, hospices that have relationships with after-hours answering services, also commonly referred to as “telephone triage” services, need to make sure that their hospices still employ and assign a sufficient number of on-call nurses who can meet the 24/7 nursing needs of their patients. When these answering services are staffed by nurses, it becomes even more important for hospices to work with their vendor to establish procedures to ensure that answering service personnel are not replacing the role of the hospice’s employed on-call nurses. In other words, hospices should be able to demonstrate through procedure and documentation that the nursing needs of their patients are being met by hospice-employed nurses.
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[Jennifer] [Kennedy], [MA, BSN, RN, CHC, ]
[Director, Regulatory and Compliance]
[National Hospice and Palliative Care Organization]
——————————Posted by NHPCO on July 17, 2015.
We at Hospice On Call exercise the utmost care to insure that all core services are provided by hospice staff while assisting the on call staff by shouldering the brunt of non clinical calls and advising caregivers on the details of the plan of care put in place by hospice personnel. All changes in plan of care or medication orders are always in the hands of hospice employees. Our hospices write the protocols which guide our service and we work closely with them to be sure that core nursing services are always in their hands.
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