5 Ways to Avoid Citation of §418.112: Overcome Challenges Coordinating The Hospice Plan of Care With A Nursing Facility

My experience in leadership is almost evenly split between hospice and long-term care. I advocated for hospice presence in every facility I was in. There is often friction on both sides of managing this relationship.

In audits of our clients records, we've found a trend with facility patients lacking components required for evidence of compliance with the conditions of participation for care plan and coordination of services.

A few simple areas create the most issues. Addressing them early and often will help prevent long-term issues that impact your relationship with facility referral sources and your survey outcomes.

Surveyors will review facility patient records looking at several areas. Per CMS Survey and Certification (stated to NHPCO), here's what they want to see with hospices and facilities caring for patients:

• Coordination
• Communication
• Collaboration

3 Areas where issues frequently occur that result in serious implications and negative patient outcomes for BOTH entities:

• Breakdown in communication of clinical observations and care needs
• Delineation of duties is unclear - who owns what interventions on the care plan? Resulting in deconditioning or decline in condition related to lack of coordination (wound care, bathing, etc.)
• The interventions, and medications and services do not correlate on both plans of care

5 Ways to show collaboration of care and avoid a citation for facility patients:

• Educate the IDT/IDG to document on collaboration and communication around the plan of care progress with the facility. "Plan of care reviewed with facility staff" at each visit.
• Build an area into your EMR as a template for facility patients!
• Ensure that the facility has the hospice plan of care and the hospice has the facility plan of care included in facility patient records and they are updated at each visit and IDt/IDG to ensure the interventions and goals are aligned.
• Hospice has a facility orientation/training/education that is reviewed regularly and with new facility contracts and their staff members.
• Create a process for contracted facilities at the agency leadership level to ensure that regular communication and collaboration occurs.

Do you have a facility orientation process in place? What has worked best for ensuring that care plans are congruent and updated in real time when changes occur?

If you need help building a process for facility education or your IDT documentation with facility patients, let us know and we'll build one for you. [email protected]

References:

? Centers for Medicare and Medicaid Services. Title 42: Public Health: PART 418—HOSPICE CARE.

? Centers for Medicare and Medicaid Services. State Operations Manual Appendix M - Guidance to Surveyors: Hospice?

National Hospice & Palliative Care Organization (NHPCO): Regulatory & Compliance Center.