Reg's Blog

Hospice Contracts in SNFs: Survey Reminders for the SNF

Due to a fair amount of travel recently, I’m a tad behind in pushing out updates, etc.  Despite my rather harried schedule, I have kept track of questions, issues, etc. and in the next week to ten days, I will endeavor to get caught up.  Please know that I do appreciate the comments and questions from readers and colleagues.

A theme that I get queried on quite a bit involves the relationship between Hospices and Nursing Homes, particularly when the SNF enters into a contract with a Hospice for the provision of hospice care to its residents.  Suffice to say that I frequently, and I have written on this subject before ( http://wp.me/ptUlY-3W ), hear concerns and misunderstandings among both providers (Hospices and SNFs) about contractual issues, care issues, documentation issues and compliance issues.  The most recent set of questions or issues comes via my wife who is a clinical consultant (RN) in long-term care.  While working with a client SNF on pre-survey preparations, she saw a number of things wrong from a compliance perspective that the SNF simply missed or misunderstood in regard to its responsibilities for its residents placed on hospice service with one or more of its hospice contractors.

Below I’ve outline the required compliance elements for SNFs when they have residents in their facilities that are on service with a Hospice agency (of course, via a contract).  These elements are taken right from the federal Conditions of Participation for SNFs and represent the essential requirements that surveyors are tasked to review.  NOTE: For SNFs it is imperative to remember that even though the primary responsibility for the careplan for a hospice patient in an SNF belongs to the Hospice, the SNF cannot transfer any compliance requirements that are its responsibility under the law to the Hospice.  The all too common theme that I hear of “he/she is now on hospice and therefore, is no longer an SNF resident” is false.

• The Hospice and SNF must communicate, establish, and agree upon a coordinated plan of care for both providers that reflects the hospice philosophy, the individual’s needs, and the unique living circumstances of the individual in the SNF. The plan must address pain and symptom management and be revised and updated as necessary to reflect changes in the individual’s care needs.  The plan must also identify the services that each provider will deliver in order to meet the needs of the patient and his/her desire for hospice care.  NOTE:  Regardless of this requirement, the Hospice is still required to provide the core hospice services (nursing, social service, bereavement, etc.) as stipulated under federal law.  The subtleties lie in the definitions of duties as delineated in the plan of care.
• The Plan of Care must reflect the following:
  • The participation of the hospice, the SNF and the resident and/or responsible party
  • The plan of care provides for pain and symptom management and clearly provides for (or has) updates reflecting the changing needs of the resident
  • Medications and medical supplies are provided for by the Hospice as required to care for the patient’s/resident’s terminal illness (requirement that the Hospice provides (or pays for) the supplies and meds related to the care of the terminal condition).
  • The Hospice and SNF communicate with each other when changes to the plan of care are required.
  • The Hospice and SNF are aware of each other’s duties and responsibilities in meeting the plan of care.
  • The SNF’s services are consistent with the plan of care and in coordination with the Hospice. The SNF resident/patient should not experience any reduction in SNF services due to his/her hospice status.
• The SNF offers the same services to its hospice residents as it does to all other SNF residents not on a hospice service.  The resident retains the right to accept or decline services offered by the SNF.
• If the SNF has concerns with the provision of service from the Hospice and the same is not satisfactorily addressed by the Hospice, it is the responsibility of the SNF to inform the appropriate licensing authority that has oversight of Hospice’s in the state.

The biggest key to take away from the above is that the SNF and Hospice need to develop a very clear plan of care, hold each other accountable for the delivery of services as outlined under the plan of care, and clearly understand each other’s duties and responsibilities under the law and as detailed in the plan of care.

September 17, 2010 Posted by Reg Hislop III | Hospice, Skilled Nursing | Compliance, Hospice, Management, Medicare, Nursing Home, Nursing Homes, SNF, survey | Comments Off on Hospice Contracts in SNFs: Survey Reminders for the SNF