Define & Refine Hospice Requirements.
Senator Ron Wyden (D-OR) and Republican Tom Reed (R-NY) have introduced The Hospice Evaluation And Legitimate Payment (HELP) Act (S. 722/H.R. 3506). Multiple Hospice associations such as National Association of Home Care & Hospice (NAHC) and the National Hospice & Palliative Care Organization (NHPCO) have requested support in contacting their State Representatives and Senators requesting their support for this Act.
The HELP Act has three main sections:
- Ensure that the transition to a new Hospice payment system is tested prior to be implemented.
- Refine requirements associated with the Hospice Face-to-Face Encounter
- Define requirements for Hospice program surveys to occur every three years
Current laws indicate that payment reform will begin on/after October 1, 2013. Currently the Centers for Medicare and Medicaid Services (CMS) is not required to test the payment reform for the purposes of understanding how it will truly impact Hospice agencies. Under this Act CMS would be required to test the payment reform with a minimum of 15-site demonstrations prior to implementing the changes.
Face-to-Face Encounter Requirements
Face-to-Face Encounters were deemed required effective January 1, 2011. With the requirements patients who are entering their third, or subsequent, benefit period must have a face-to-face encounter with a Hospice physician or nurse practitioner (NP). Under the current guidelines Hospice agencies have up to two days to complete the face-to-face documentation if there are “exceptional circumstances.” Still, Hospices are struggling to meet the timeframes of the face-to-face requirements. Under this Act agencies would have an additional seven days to complete the face-to-face requirements when “exceptional circumstances” exist. In addition, it would allow physician assistants to perform the face-to-face encounter.
Hospice Program Surveys
It is reported that most Hospices, today, are surveyed every six to eight years. With the continuing changes in regulations and requirements it’s important that agencies have more frequent surveys to ensure providers are following the survey and certification requirements that have been defined. As such, with this Act the recommendation is for all Hospices to undergo surveys every three years. This would be in line with industry standards set forth by accrediting organizations, such as the Joint Commission for the Accreditation of Healthcare Organizations (JCAHO).
We urge you to contact your State Senators & Representatives to ask them to support this Act.
Do all of the changing requirements have you worried about your agency’s compliance? HEALTHCAREfirst solutions offer CMS compliant solutions that will not only help you meet the requirements, but enable you to focus on what you do best: Care for patients. Contact us today for more information.