What Should Hospice Chaplains Expect After Changes Were made to Hospice Quality Reporting Program for 2021?

James Evans

The Centers for Medicare and Medicaid Services has made alterations to the Hospice Quality Reporting Program , created to analyze hospice organizations’ reporting data in an effort to standardize a level of quality care.

Hospice Quality Reporting Program data is pulled from two sources:

  1. The Hospice Item Set, documentation completed by hospice providers.
  2. The Consumer Assessment of Healthcare Providers and Systems, a survey completed by caregivers or families of hospice patients.

There are four major changes that will impact hospice organizations this year, including the role of the interdisciplinary group (IDG), which was formed as a well-rounded approach to a patient’s plan of care and end-of-life goals, as well as processes that ensure the patient’s medical, non-medical and psychological needs are met.

Four Major Changes to the Hospice Quality Reporting Program this year

1. Removal of Section O in the Hospice Item Set- Discharge Assessment

A measure pair known as Hospice Visits When Death Is Imminent is a requirement for Medicare compliance. The first measure required at least one visit from a registered nurse, physician, nurse practitioner or physician’s assistant in the final three days of the patient’s life. The second measure analyzed the percentage of patients who received at least two visits from a social worker, hospice chaplain or counselor, licensed practical nurse or hospice aide in the last seven days of the patient’s life.

After analyzing results, the first measure set from Section O passed standard quality requirements. The seven-day measure didn’t meet readiness standards for CMS, so the entire section was replaced.

2. Introducing the Hospice Visits in the Last Days of Life Measure

Section O is being replaced by Hospice Visits in the Last Days of Life, a measure that analyzes the proportion of hospice patients who received visits from a registered nurse or medical social worker in at least two of the last three days of life.

This replacement, launched on January 1, 2021, will only pull data from required Medicare visits, making it a claims-based measure, not necessarily the previously required quality-based measure pair.

3. What does this mean for the interdisciplinary group?

End-of-life visits from non-medical participants of the IDG are no longer required by Medicare. Removing spiritual care counselors, core members of the IDG, eliminates a level of quality care that regular medical visits perhaps cannot fulfill. Some organizations believe that claims-based measures do not capture the entirety of the patient’s experience in hospice with members of the IDG, where each aspect of the patient’s needs could be satisfied.

Ideally, hospice chaplains and counselors will feel invested in the comfort and emotional state of their patients and feel led to be at their side. However, this benefit is no longer inevitable.

4. Patient Access During the COVID-19 Public Health Emergency

The new Hospice Visits in the Last Days of Life requirement states that the two patient visits in the last three days of life must be in person. During this COVID-19 public health emergency, access to hospice beneficiaries inside nursing homes is limited. While CMS has provided guidelines to nursing homes on how to safely allow outside medical workers, discretion is left to the individual business, and some are choosing to keep their doors closed.

When these situations occur, hospice professionals turn to telehealth to connect with patients, a type of visit that is not eligible under the new Medicare guidelines.

The Future of IDG in Hospice Care Is Left to the Providers

The replacement of the Hospice Visits in the Last Days of Life measure pair allows for fewer visits during the patient’s last days, with some core members of the IDG left out altogether. This could have unfortunate implications for hospice patients who might want a hospice chaplain to be with them during their last days or a counselor to comfort and advise their family.

However, hospice organizations are busy. Patients are many, while workers are few. If a visit is not required to meet compliance and avoid reductions in reimbursement, workers are often prioritized for required visits.

IDG meetings could look different, with some core members no longer required throughout the patient’s lifespan. They could be shorter, with only a physician, registered nurse and medical social worker as the vital members at this stage. While still required to be present, the hospice chaplain may have less input regarding patients nearing the end of life.

IDG was formed to provide both medical and non-medical services throughout the entirety of hospice care, but that is changing. It is up to hospice professionals to prioritize patient visits and keep in mind the reason they felt led to work in hospice care: to provide compassionate care during a fragile time.

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