See Something Say Something: Mandatory Reporting!

See Something Say Something: Mandatory Reporting!

What is mandatory reporting?

Hospice clinicians advocate for their patients and their patients’ families. As a clinician, one of the most important ways that you can advocate for their patient is by engaging in mandatory reporting when you observe or suspect that your patient is being neglected or abused.

What is a mandatory reporter?

A mandatory reporter has an individual duty to report known or suspected abuse or neglect relating to children, dependent adults, or elders. These include:

  • A child is anyone who is under 18 years old
  • A dependent adult is anyone between 18 and 64 years of age who has physical or mental limitations that restrict their abilities to carry out normal activities or protection of their rights
  • An elder is anyone 65 years of age or older

A reporter should report good faith beliefs or reasonable suspicions of abuse or neglect.  The report will be confidential, and the identity of the reporter will be hidden from the public.

Who are mandated reporters?

State-specific laws specify several professions of mandatory reporters. These include professions such as:

  • Social workers
  • Teachers
  • Healthcare workers
  • Law enforcement
  • Childcare providers
  • Medical professionals
  • Clergy
  • Mental health professionals

The list of professions of mandatory reporters varies by state.

What is abuse?

Although we often think of abuse as physical abuse, remember that abuse can come in all different forms.  For example, forms of abuse include:

  • Physical abuse
  • Mental anguish
  • Financial abuse
  • Sexual abuse
  • Emotional abuse

Protect your patients by looking out for all of these different forms of abuse. No one deserves to be subject to any form of abuse.

How can you best protect your patient?

To best protect your patients, constantly be aware and on the lookout for any types of abuse or neglect. Hospice patients are vulnerable since they are often physically frail, dependent on others around them for support and care, and unable to advocate for themselves.  As a healthcare worker, you need to advocate for your patient in the case of suspected neglect or abuse. 

Continually assess the patient for any signs of abuse or neglect. Look out for any unusual behaviors. Follow any of your agency’s protocols in documenting any observations and conversations. If you identify concerns, share these concerns with the appropriate individual in your agency.

How do you report?

If your agency cannot provide you with clear guidance about how to report the suspected abuse or negligence, each state has websites that can provide you with that guidance. Each state has specific requirements on what you must report, required timing of reporting, and the like.

In addition, most states have reporting hotlines. Remember to be detailed and accurate when you file the report and to provide all the required information. 

Why is it important for you to report?

Sometimes, you “may not want to bother” to report suspected abuse or you may feel “it is not your business to get involved”. However, here are two key considerations:

  • As a healthcare worker and medical professional, you are a mandated reporter and as such, by law, you have a duty to report known or suspected abuse or neglect
  • As a patient advocate and healthcare professional, you have an ethical duty to report instances of known or suspected abuse or neglect

Identifying abuse or neglect as early as possible is critical for the physical and mental health of the abused or neglected individual. Your actions can have profound positive consequences on your patient’s life. Remember: if you see something say something!

Where can you find out more?

Improving your Organization with FAST Goals

Improving your Organization with FAST Goals

Goals have come to dominate our modern workplace. Goals are a way of breaking down business plans into smaller more manageable pieces. This enables an organization to accomplish some of the targets and plans that were specified during their planning cycle.

Organizations set strategic goals, teams set team goals, and employees set individual goals. Team goals and employee goals should be aligned with and supporting the organizational strategic goals.

A common practice is that goals are set early in the year and then, at the end of the year, achievement against those goals is measured.  For example, an employee will usually meet with his or her manager early in the year to define goals for the year. Then, at the end of the year the employee is measured against the stated goals that were set at the beginning of the year.  Further, employee bonuses are frequently tied to the successful completion of their defined goals.  The widely accepted understanding is that goals should be SMART: specific, measurable, achievable, realistic, and time bound.

Is this the best approach?

SMART goals are widely used to implement strategies and monitor performance, but research suggests that some elements of SMART goals may hinder an organization’s broader objectives.

The first consideration is the overall timeline of the process. SMART goals are set once and then individuals and teams work throughout the year to achieve these goals. However, this approach overlooks the value of ongoing discussions throughout the year. In today’s fast-changing environment, failing to regularly revisit and adjust goals can be a significant risk for organizations. 

Another consideration is the achievable aspect of SMART goals and the fact that employee end of year compensation is tied to achieving goals. Employees often set overly conservative goals to ensure success, stifling ambition and overall organizational success.

Finally, this process does not encourage collaboration, which is a key element to achieving organizational success. When individuals and teams set their own goals that are not shared with others in the organization, there is a risk of misaligned goals across different individuals and teams within the organization.

FAST goals can help to overcome some of these downsides of SMART goals.

What are FAST goals?

  • Frequently Discussed: Short term goals that allow for faster evaluation and achievement cycles, with multiple review cycles throughout the year. Progress toward the goal and resources allocated toward the goal are discussed on a regular basis. The feedback loop enables fast modifications, as required.
  • Ambitious: The goals are possible to achieve but stretch you a little – just past your point of comfort. Goals that are challenging yet achievable with effort — commonly referred to as stretch goals —motivate us to strive toward achieving them.
  • Specific: The goals have concrete milestones and metrics. This way you can measure how much progress you have made toward achieving the goal.
  • Transparent: The goals should be available for view across the organization. Employees should feel comfortable sharing their goals with team members and those outside their team. This encourages accountability and drives the organization to meet its overall strategic goals. This also helps to overcome the risk of misaligned goals.  Finally, if an element of bonus or profit sharing is tied to the organization meeting its overall strategic goal, transparency allows and encourages individuals and teams to provide support across the organization, also increasing the likelihood that the organization will meet its strategic goals.

What are the benefits of FAST goals?

FAST goals benefit employees by fostering a sense of purpose and connection to the organization’s larger mission, boosting morale and engagement. The emphasis on regular feedback and collaboration helps employees feel supported and valued, while ambitious yet achievable goals encourage growth and innovation without fear of failure. This approach creates a positive work environment where individuals are motivated to excel and contribute meaningfully to the team’s success. All of this contributes to the success of the organization and helps the organization achieve its organizational goals.

In today’s rapidly evolving workplace, FAST goals offer a modern approach to goal-setting that emphasizes agility, alignment, and accountability. By focusing on frequent discussions, ambitious yet achievable objectives, and transparent tracking, FAST goals drive collaboration and innovation across teams. Unlike traditional methods, this approach encourages employees to stay adaptable and aligned with organizational priorities, even in dynamic environments. As businesses continue to navigate change, adopting FAST goals can be a powerful strategy to foster growth, improve performance, and achieve long-term success.

Where can you find out more?

  • MIT Management – Strategic Agility
  • Video – What are SMART goals?
Legal Risks of Retaliation: How to Handle Employee Complaints Safely

Legal Risks of Retaliation: How to Handle Employee Complaints Safely

When an employee brings forward a compliance concern, they’re engaging in what the law defines as protected activity. This might involve reporting a potential violation of hospice regulations, concerns about Medicare fraud, or even raising issues about unsafe working conditions. These are rights guaranteed under various laws, like the False Claims Act, OSHA protections, and Title VII of the Civil Rights Act, which protect employees who speak up.

In responding to employee concerns, there is a fine line between addressing workplace concerns and crossing into retaliation territory. Retaliation isn’t always a blatant act of revenge. Sometimes, it’s more subtle, even subconscious. Sometimes management at the hospice agency may feel frustrated or betrayed by an employee’s complaint and – without realizing it – allow those feelings to influence their decisions. Maybe the employee was already struggling with performance, or maybe there were pre-existing tensions on the team. But when an adverse action—like firing, demotion, or cutting hours—happens shortly after a complaint, it’s easy for that decision to be seen as retaliatory, even if it wasn’t intended that way.

What is Retaliation?

To clarify what retaliation means, it’s any adverse action taken against an employee because they engaged in protected activity. Timing is a major red flag here. If an employee files a compliance report and is terminated shortly after, it raises questions. Even if you feel justified in your decision, the timing alone can look suspect to a court, regulatory agency, or even the employee’s peers.

What are the Consequences of Retaliation

And the consequences for retaliation? They’re not just legal—they’re also reputational. If a claim is brought against an agency, the agency could face:

  • Reinstatement of the employee to their position, even if you’ve moved on.
  • Back pay, damages, and legal fees, which can quickly add up.
  • Regulatory scrutiny, which might open the door to deeper investigations into the agency’s practices.
  • And, perhaps most damaging, the perception that we don’t care about compliance or employee rights. That’s not a message we can afford to send.

From the employee’s perspective, they have a number of options if they feel they’ve been retaliated against. They might file a complaint with OSHA, EEOC, or state regulators. They could seek legal action for wrongful termination or take their concerns to external auditors or even the media. Once that door is opened, the hospice agency loses control of the narrative.

How Can You Avoid Retaliatory Behavior?

So, what can you do to avoid even the appearance of retaliation? Here’s are some suggestions:

  • Document everything: If there are performance concerns or other issues unrelated to the complaint, make sure there’s a clear, consistent record. This documentation can be your best defense.
  • Separate decision-making: If you’re in the middle of handling a compliance complaint, let someone outside the situation—like your compliance officer or HR—review any proposed actions against the employee.
  • Follow established protocols: Deviating from your normal policies, especially when dealing with someone who has raised a complaint, can make it look like you are targeting them.
  • Train your leaders: Everyone in management needs to understand what retaliation looks like and how to avoid it.

Leadership sometimes expresses concerns about employees “stirring up trouble” or raising issues for self-protection. But the law doesn’t distinguish between “valid” and “troublesome” complaints. Protected activity is protected activity, full stop.

Take a step back. If you’re ever considering taking action against an employee who has engaged in protected activity, discuss it first with your HR or compliance team. Together, you can ensure the decision is based on legitimate, well-documented reasons and not influenced—even unconsciously—by the complaint itself.

At the end of the day, your goal is to serve patients and families with integrity and compassion. That means creating a culture where employees feel safe to speak up about compliance issues without fear of retaliation. Protecting that culture isn’t just about avoiding lawsuits—it’s about doing what’s right for your team, your agency, and the people you care for.

What is a Hospice IDG Meeting and Who Should Attend

What is a Hospice IDG Meeting and Who Should Attend

The hospice interdisciplinary group (IDG) creates a patient’s plan of care and provides holistic care to the patient, caregiver, and family. Hospice Conditions of Participation require the IDG to “review, revise, and document the individualized plan as frequent as the patient’s condition requires, but no less frequently than every 15 calendar days.”

As such, the IDG meet at a minimum every 15 days. In many hospice organizations, the interdisciplinary group meets weekly to review patient status and to determine if changes are required to a patient’s plan of care.  It is important that during the IDG meeting patients’ care plans are reviewed and updated based upon patients’ assessments. Timely and accurate documentation is critical; this documentation may be reviewed by surveyors and by CMS to ensure compliance with regulations.

Who is required to attend an IDG Meeting

Required members of the IDG meeting include:

  • A doctor who is an employee or under contract with the hospice agency
  • Registered nurse
  • Social worker
  • Pastoral or other counselor

These four individuals are minimum participants in the IDG meeting. If one of these members i missing from the IDG meeting, the meeting does not meet Medicare regulations and it is considered as if the meeting did not take place. . Care must be taken to ensure that the minimum requirement – IDG meeting with the participation of at least these four individuals at a minimum of once every 15 days – is met.

Additionally, a staff member is typically identified to serve as the scribe for the IDG meeting. The scribe captures any changes to a patient’s plan of care that are agreed upon during the meeting.

What activities occur during the IDG meeting?

When the meeting begins, all participants sign the meeting sign-in sheet. These sheets serve as documented proof that the hospice has met the Medicare Conditions of Participation – that the required members of IDG participated in the meeting. Sign in sheets are stored in a place that is accessible for review upon the request of auditors or surveyors.

Prior to the IDG meeting, a list is drawn up of the patients who will be reviewed during the meeting. For each of these patient’s members of the care team provide an update on the patient’s current condition, highlighting any concerns. The team then discusses the plan for the upcoming two weeks.

Patients may be ordered for discussion as follows:

  • Deaths
  • Admissions
  • Recertifications
  • Evaluation

Let’s review each of these in detail.

Deaths

Each death since the prior IDG meeting is reviewed. The team discusses whether bereavement has been requested or declined. In the case where bereavement has been requested, the individuals who will be receiving bereavement services are identified. Any further details or concerns on the services that will be provided are discussed.

Admissions

The RN Case manager discusses any new admissions since the prior IDG meeting, including patient diagnosis and hospice eligibility criteria. Visit frequency is discussed, hospice aide services, and patient psychosocial needs. Typically, all team members partake in this discussion including a discussion about patient medications and prognostic indicators.

Recertifications

At this stage in the IDG the team discusses all patients who are the end of their benefit period and need to be recertified. Any face-to-face visits that were conducted will be discussed and any that are still pending will need to be scheduled. For patients who were evaluated and are found not to meet criteria, the team discusses how to notify the family and details on how to transition the patient off of hospice care.

Evaluations

All remaining patients on the list are reviewed by the members of the IDG. The team discusses whether any changes to the plan of care are needed, whether any medications need to be changed or if any additional support is required (e.g., chaplain, volunteer). The plan of care may be updated if the team agrees that a change in visit frequency is required.

Updating patients’ plan of care

While each patient is discussed, any changes to the patient’s plan of care are entered into the patient’s chart, which is signed by the medical director.

Hospice Interdisciplinary Group (Hospice IDG)

Hospice Interdisciplinary Group (Hospice IDG)

Hospice care is patient- and family-centered, where the patient’s and family’s preferences and needs drive the care plan.

The hospice interdisciplinary group (also referred to as Hospice IDG or IDG), also referred to as the interdisciplinary team (IDT) is a team of healthcare professionals who work together to create a plan tailored to the needs of hospice patients. The IDG is crucial because it reflects the fundamental principle of hospice care: a multidisciplinary and holistic approach to treating a patient. Hospice care is not just about managing medical symptoms; it involves addressing the physical, emotional, social, and spiritual needs of the patient and their family. This comprehensive care model requires combined expertise of different healthcare professionals working together as a cohesive team.

Multidisciplinary and 360-degree approach

The idea of a multidisciplinary approach is central to hospice care because a single healthcare professional cannot fully address the complex needs of a patient at the end of life. Hospice patients often experience pain, emotional distress, social isolation, and spiritual concerns, all of which need to be treated so that the patient has a peaceful and dignified end of life experience. Each of the members of the IDG can address different aspects of hospice patient needs.

Physical needs: Managed by the physician and nurse. The physician provides medical direction and oversees patient care while the nurse manages the patient’s medical needs such as pain control and symptom management.

Emotional and social needs: The social worker provides emotional and social support, caring for emotional health, caregiver stress, and family dynamics. Consideration is also given to connecting the family with community resources

Spiritual needs: These are managed by the chaplain, who offers spiritual care and counseling, based on the patient’s and family’s beliefs.  The chaplain helps patients and families explore spiritual concerns, questions of meaning, or religious beliefs in the context of their journey.

Daily living needs: Hospice aides assist with personal care like bathing, dressing, and grooming. They ensure dignity and comfort in activities of daily living like bathing, dressing, and grooming.

Companionship and support:  The hospice volunteer offers companionship and practical help, like errands or respite for family caregivers.

By involving individuals from different disciplines, hospice care can take a 360-degress approach to a patient’s needs. It means that every aspect of care – physical, emotional, social, and spiritual – is addressed by someone with the expertise to manage that particular dimension. This all encompassing approach is what makes hospice care unique and effective.

Are all member of the IDG required per CMS regulations?

Per CMS regulations, only core members must always be part of the IDG to ensure that hospice care addresses every critical aspect of the patient’s experience. Four disciplines are considered core required members of the team. These include:

  • Physician
  • Registered nurse
  • Social worker
  • Chaplain

Some professional members may be included in the IDG as needed, depending upon patient’s individual circumstances. These include:

  • Hospice Aide
  • Volunteer
  • Therapists
  • Bereavement Counselor

How is the IDG aligned with regulatory standards?

CMS requires that hospice care involve an interdisciplinary approach because it reflects the need to treat the “whole” patient, not just their medical condition. The IDG ensures that the care plan is tailored to the patient’s evolving needs and that it incorporates feedback from multiple disciplines to achieve the best outcomes. The interdisciplinary model is also a regulatory requirement under the hospice Conditions of Participation (CoPs). As such, surveyors will review the functioning of the IDG during inspections to ensure compliance. A well coordinated interdisciplinary team ensures regulatory compliance and quality patient care.

Why is the interdisciplinary hospice team essential?

 

Hospice care is patient and family centered, meaning that the patient’s and family’s preferences and needs drive the care plan. The IDG works collaboratively to ensure that the care plan remains flexible and responsive to changes in the patient’s condition. As hospice patients often experience rapid changes in health, having professionals from different disciplines ensures that all aspects of care can be addressed promptly and effectively.

In summary, the IDG reflects hospice’s holistic, multidisciplinary approach to care by ensuring that all dimensions of the patient’s well-being are addressed. Required team members focus on medical, emotional, and spiritual care, while optional members can be added to meet unique or additional needs. This alignment ensures that hospice remains flexible and patient-centered.

Pay Transparency: What Managers Need to Know

Pay Transparency: What Managers Need to Know

As a manager in hospice care, your role goes beyond overseeing patient care and managing staff. It includes ensuring that your team feels valued and fairly compensated. Pay transparency is becoming a hot topic, and understanding its implications can help you effectively navigate this evolving landscape.

What Is Pay Transparency?

Pay transparency refers to the practice of openly sharing information about compensation within an organization. This can include posting salary ranges in job listings, discussing pay openly among employees, or providing detailed breakdowns of how pay is determined. The goal is to ensure that employees understand how their pay is calculated and that there are no disparities based on gender, race, or other factors.

What is the status of pay transparency regulations in the U.S.?

The U.S. is starting to experience a trend in adoption of pay transparency regulations. Several states have introduced laws that require employers to provide salary ranges in job postings or upon request. For example:

  • Colorado: The state’s Equal Pay for Equal Work Act requires employers to include salary ranges in job postings and provide pay information to employees upon request.
  • New York City: The city requires employers with four or more employees to include salary ranges in job advertisements.
  • California: As of January 2023, California employers with 15 or more employees must include pay scales in job postings.

It is likely that more states will follow and that the laws with transparency requirements will continue to be more comprehensive.

Why Is Pay Transparency Important?

  • Fosters Trust and Engagement: When employees understand how their pay is determined and believe it is fair, they are more likely to feel valued and engaged in their work. In a field as emotionally demanding as hospice care, high employee engagement is crucial for maintaining a positive work environment and delivering high-quality care.
  • Reduces Pay Disparities: Pay transparency helps to identify and address pay disparities that may exist within your organization. In healthcare, where women and minorities are often overrepresented in lower-paying roles, transparency can be a tool for promoting equity and ensuring that all employees are paid fairly for their work.
  • Compliance with Regulations: Some states in the U.S. are implementing laws that require employers to provide pay ranges in job postings or share salary information upon request. Staying ahead of these regulations by adopting pay transparency practices can help your hospice avoid legal challenges and demonstrate a commitment to fairness.

How to Implement Pay Transparency

  1. Review Current Pay Practices: Start by conducting a thorough review of your current pay practices. Ensure that salaries are consistent with market rates and that there are no unexplained disparities among employees with similar roles and experience levels.
  2. Communicate Clearly: If you decide to move towards more transparency, communicate clearly with your team about what information will be shared and why. For example, explain how pay ranges are determined and what factors influence individual salaries.
  3. Train Managers: Provide training for all managers to ensure they understand the principles of pay transparency and are equipped to have open and honest conversations about pay with their team members.
  4. Update Job Postings: If your state requires it or if you choose to do so, include salary ranges in job postings. This not only meets regulatory requirements but also attracts candidates who appreciate transparency and fairness.
  5. Regularly Review and Adjust: Pay transparency is not a one-time effort. Regularly review your compensation practices and make adjustments as needed to ensure ongoing fairness and compliance with any new laws or guidelines.

Challenges of Pay Transparency

  • Managing Expectations: One of the challenges of pay transparency is managing employee expectations. If employees see that their pay is lower than a colleague’s, they may feel undervalued, even if there are legitimate reasons for the difference. It’s important to be prepared to explain these differences clearly and fairly.
  • Confidentiality Concerns: In some cases, employees may prefer to keep their salaries private. It’s important to balance transparency with respect for individual preferences and privacy.
  • Complexity in Pay Structures: Healthcare organizations often have complex pay structures with various factors influencing salaries, such as certifications, years of experience, and additional responsibilities. Transparency requires clear communication about these complexities, which can be challenging.

The Future of Pay Transparency in the U.S.

It is likely that the U.S. will continue to see increased pressure for transparency in the coming years. The healthcare industry, including hospice care, may need to adapt to more stringent regulations and expectations around pay disclosure.

As a manager, staying informed about these trends and proactively implementing transparent pay practices can position your hospice to lead in this area. Not only will this help in complying with potential future regulations, but it will also foster a more equitable and supportive work environment for your team.

Conclusion

Pay transparency is an important and evolving issue. Adopting transparent pay practices now can help foster trust, promote fairness, and ensure compliance with current and future regulations. By being proactive in this area, you can create a more equitable and positive work environment for your team, ultimately leading to better care for your patients.

Where Can You Find Out More

  • Gallagher: How managers can respond to pay transparency
  • SHRM: How Companies can Respond to New Pay Transparency Laws
  • Payscale: How to implement pay transparency
  • World at Work: Pay Transparency – Risk, Rewards, and Regulations
  • Harvard Business Review: Complicated Effects of Pay Transparency