Hospice

Good morning. 

The long-awaited revised hospice survey process and updated interpretive guidance is now available at the following link: https://www.cms.gov/medicare/provider-enrollment-and-certification/surveycertificationgeninfo/policy-and-memos-states/revisions-hospice-appendix-m-state-operations-manual-and-hospice-basic-surveyor-training

via QSO memo which was posted this morning.  The revisions are effective immediately although survey directors have 30 days to communicate the changes to their staff.  The revisions contain only minor references to enforcement remedies (such as civil money penalties) so we expect additional information related to this area of the survey process will be available at a later date.

The revisions focus the survey on quality of care and break the conditions of participation into two phases:

• Phase I identifies CoPs that contribute to understanding the quality of care delivered directly to patients, their caregivers, and families.
• Phase II identifies CoPs that, while still integral to the survey process, focus more on the administrative functions and operations of hospice services.  

All CoPs continue to have equal weight but special attention is directed to those Phase I CoPs directly impacting patient care. Phase 1 CoPs include:

§418.52 Patient Rights,

§418.54 Initial and comprehensive assessment of the patient and

§418.56 Interdisciplinary Group, care planning, and coordination of services.

NAHC staff are analyzing the changes and will provide a detailed summary soon.