by editor | Nov 7, 2022 | Compliance and Regulatory - Directors, Documentation - Nurses, Hospice 101 - Nurses, Metrics and KPIs, Rules and Regulations - Nurses
What is the CAHPS hospice survey?
The CAHPS hospice survey is administered to eligible caregivers after a patient’s death to measure the quality of care and communication provided by the hospice. A hospice agency must participate in the CAHPS Hospice Survey to be eligible for its full annual payment update (APU). Failure to participate will result in a 2% reduction in APU. For example, compliance with the 2022 CAHPS Hospice Survey affects fiscal year 2024 APU.
Are all hospices required to administer the CAHPS hospice survey?
All Medicare certified hospice agencies should participate in the CAHPS hospice survey with two exceptions:
- Size Exemption: The exemption is based upon the number of decedents the hospice served in the prior calendar year. If the hospice served fewer than 50 survey eligible decedents or caregivers in the prior calendar year, the hospice is exempt from the CAHPS hospice survey
- Age Exemption: The exemption for age of hospice is based upon the date that the hospice received its CCN. The hospice is exempt for the remainder of the calendar year in which it receives its CCN.
CMS identifies hospices that are exempt due to age. A hospice agency is not required to file a form to request Age Exemption.
CMS does not identify hospices that are exempt for due to size. A hospice agency must apply for a Size Exemption and must apply for the Size Exemption each year that it wishes to be eligible for this exemption.
How does a hospice apply for a Size Exemption?
The hospice must complete a Participation Exemption for Size Form. The form, deadlines for submission, and details for completion can be found here.
The form requires not only a count of total patients who died while in hospice care, but certain details about these patients to determine the count of survey eligible patients and caregivers. For example, the hospice will need to submit counts of the number of patients
- who were under 18 when they died
- where there is no caregiver on record
- who died within 48 hours of final admission to hospice care
and several other categories. Care must be taken that patients are only counted in one of the categories even if they fall into multiple categories, to eliminate double counting.
What happens once a hospice submits a size exemption form?
Immediately upon submission of the form, the CAHPS Hospice Survey Project team will confirm receipt of the form. This confirmation, however, is not equivalent to Size Exemption approval. CMS will review the data to determine if the exemption is met. If CMS determines that the exemption is not met, the hospice is responsible for survey administration. Hospice agencies must accurately complete the Participation Exemption for Size Form so that they are not faced with a rejection by CMS. If the Size Exemption is not met and the hospice agency has missed administering and submitting surveys, the hospice agency will face an APU reduction.
Where can you find more information?
by editor | Nov 7, 2022 | Compliance and Regulatory - Directors, Documentation - Nurses, Hospice 101 - Nurses, Metrics and KPIs, Rules and Regulations - Nurses
Why should a hospice agency use a CAHPS Hospice Survey vendor?
A hospice agency is not permitted to administer its own CAHPS Hospice Surveys. Instead, every hospice agency is required to contract with an approved CAHPS Hospice Survey vendor. The vendor will administer the CAHPS Hospice Survey on an ongoing monthly basis and submit the data.
How can a hospice agency find an approved CAHPS Hospice Survey vendor?
CMS provides a list of approved vendors, which can be found here
Tips for selecting a survey vendor
The results of the CAHPS survey are publicly reported on Care Compare. Further, failure to submit the data timely can result in penalties from CMS. Given the significance of this survey, it is important to choose a reliable and experienced vendor that understands the hospice industry and can ensure both the quality and compliance of the data that will be submitted to CMS.
Some factors to explore when evaluating vendors include:
- Maturity of the vendor’s business and its processes. When was the business formed, number of clients, number of surveys, technologies used, operational failures, and growth in staff/changes in operations in support of growth in client base.
- Conducting the Surveys. What are survey response rates, languages supported, and mediums supported.
- Data sharing. How will patient files be shared with the vendor, does the vendor work with your EMR, is there a secure way to transmit data.
- Data Security. Has the vendor ever had a data breach, what steps are taken to ensure data protection, what steps are taken to ensure no data loss, how is data backed up, in the event of a failure how quickly will data be restored.
- Data Insights. Finally, with respect to insights, what analysis is performed on the data, what reports or dashboards does the vendor provide, does the vendor help the agency understand the results.
- Fees and Billing. Models for fees for CAHPS surveys vary by vendors. Examples may be flat price billing, fee per completed survey, fee per caregiver. Additional fees may be charged for follow ups, detailed reporting to the hospice agency, analysis shared with the agency, or access to survey data, for example.
Notifying CMS of the selected vendor
A hospice agency is required to complete a form that authorizes the CAHPS Hospice Survey vendor to collect and submit survey data to CMS. If the hospice agency does not notify CMS of this authorization, the vendor may not submit the data on behalf of the agency.
The CAHPS Hospice Survey Vendor Authorization Form is used to notify CMS of vendor authorization. The form and instructions for submission can be found here
The Vendor Authorization Form must be signed and notarized. The individual who signs the form is considered the CAHPS Hospice Survey Administrator for the hospice agency. An additional individual in the agency may be designated on the form as the primary point of contact for the survey.
Timelines
The Vendor Authorization Form must be submitted three months before data is required to be submitted.
For example, patients who die between January 2023 and March 2023 will be contacted for survey between April 2023 and June 2023. Their data will be due for submission to the CAHPS Hospice Survey Data Warehouse on August 9, 2023.
If an agency is first contracting with a vendor to begin service in January 2023, the Vendor Authorization Form would need to be submitted by May 9, 2023.
Where can you find more information?
by editor | Oct 21, 2022 | Compliance and Regulatory - Directors, Recruitment and Retention, Rules and Regulations - Nurses
What is a hospice volunteer?
Hospice volunteers are key contributors to a hospice agency. The hospice movement was started with volunteers and there are now more than 460,000 volunteers nationwide. To retain the initial spirit of hospice, Medicare requires that volunteers must provide services that equal at least 5% of the total patient care hours of all paid hospice employees and contract staff. Hospice volunteers are used to perform day-to-day administrative tasks for the hospice agency or in direct patient care roles.
Where can you recruit to find volunteers?
How should a hospice screen potential volunteers?
There are a number of areas the hospice agency should consider when screening potential hospice volunteer’s:
- What is motivating the potential volunteer?
- What skills does the potential volunteer have?
- How much time does the potential volunteer have available?
- Is the potential volunteer willing to complete any necessary training?
- What is the potential volunteer’s degree of comfort with concepts surrounding death and dying including death, loss, grief, and bereavement. Does the potential volunteer have a healthy adjustment to significant loss?
- Does the potential volunteer have a capacity for empathy and sensitivity?
Considerations for retaining volunteers
If your agency has a wonderful team of volunteers, you want to be sure not to lose this group. How can you increase the chance of retention? Just like employees, retaining volunteers takes effort! Here are some tips for increasing the chance of retaining your volunteers:
- Hospice volunteers need to believe in the hospice mission.
- They should see an opportunity for personal or professional growth
- Volunteers should feel needed and feel that they are contributing – the the agency or to the patients that they care for
- Volunteers should feel supported by the hospice agency staff
- Volunteers should be able to share the emotional events that they may experience while they volunteer
by editor | Oct 20, 2022 | Compliance and Regulatory - Directors, Reports, Rules and Regulations - Nurses
Volunteers are an essential components of hospice. The hospice movement was started by volunteers. There are currently more than 460,000 hospice volunteers nationwide. Volunteers provide administrative support or direct patient care services.
Are hospices required to have volunteers?
Use of volunteers is a Medicare condition of participation. Medicare requires the use of hospice volunteers for any Medicare certified hospice. Volunteers must be used in day to day administrative tasks that support direct patient care activities and/or in direct patient care roles.
For each hospice agency, volunteer hours must equal 5% of total patient care hours for all paid hospice agency employees and contractors. A hospice must maintain records of the number of hours worked by volunteers as well as the types of activities performed and whether these activities were administrative or patient care.
The hospice volunteers must perform their activities under the supervision of a designated hospice employee.
Are there other volunteer-related requirements?
There are additional training and documentation requirements that a hospice agency must meet, relating to hospice volunteers:
- A hospice must provide orientation and training for its hospice volunteers and this training must documented
- Efforts to recruit volunteers on an ongoing basis must be documented
- Cost savings achieved through the use of volunteers must be documented. The documentation must include the volunteer’s position, the time spent by the volunteer, and the estimated dollars that would have been spent by the hospice had this position been filled by a paid hospice employee
What direct patient care activites are performed by a volunteer?
Volunteers travel to the location where the patient currently resides – such as the patient’s home, a nursing home, or an assisted living facility – and work directly with patients, caregivers, and families. These volunteers are considered direct care volunteers. Examples of direct care activities include:
- Performing light household chores
- Cooking meals
- Provide transportation for patients or their families
- Provide companionship to the patient
- Providing respite so that family caregivers can take a break
- Using some special skills that the volunteer has such as giving a manicure, giving a haircut, playing a musical instrument, doing an art project with the patient, and the like
- Travel time to the patient’s home may also be included in volunteer hours, if travel time is also used in the calculation of hospice employee hours
- Time a volunteer
What indirect care activities are performed by a volunteer?
Volunteers can also have an impact without directly interacting with patients. For example, they can prepare items that are delivered to patients, they can advocate for hospice patients in the community, or they can go to volunteer health fairs. Indirect care hospice volunteers can also assist the hospice agency with administrative and general office tasks. Examples of indirect care activities include:
- Assisting with preparing mailings for community outreach
- Assisting with data entry, filing, copying, or other clerical duties
- Answering phone calls,
- Preparing blankets to be delivered to hospice patients
- Helping setup for community events
- Helping with grief support groups
What activities may be included in the calculation of volunteer time?
There activities that may be included in total hospice volunteer hours are varied. For example:
- Time that the volunteer is performing the actual tasks (such as assisting with mailings, data entry, light housekeeping, etc.)
- Telephone calls to hospice patients, their family members, caregivers, or bereaved family members
- Travel time to patient homes, if this travel time is included in the calculation of hours for hospice employees
- Time spent receiving orientation to a specific patient
- Time spent in training to perform specific tasks
What activities may not be included in the calculation of volunteer time?
Recall that volunteers must be used in day to day administrative and or direct care patient roles. So the following are examples of activities that would not be included in the calculation of total volunteer hours:
- Flower arranging
- Working in a thrift shop
- General volunteer training that is not specific to a patient or to an administrative task
- Participation in the agency’s governing board
Where can you find out more?
by editor | Oct 18, 2022 | Billing, Billing - General, Compliance and Regulatory - Directors, Medical Records, Rules and Regulations - Nurses
What is a hospice election statement?
A hospice election statement is a condition of payment under Medicare. For a patient to be eligible to receive hospice services under the Medicare benefit, the patient or the patient’s authorized representative must elect hospice care by signing a hospice election statement. While Medicare provides a model of this form, each hospice agency is free to design their own hospice election form. However, there are some required elements, as specified by Medicare. To find out more details about the hospice election statement, read more at our blog post here: What is the Hospice Election Statement requirement?
Why is the hospice election statement important?
An invalid hospice election statement can impact payment for the entire patient hospice stay. There has been a recent rise in denials related to the election form. As such, it is important for hospice agencies to ensure that all required elements are present on the form and that the forms are completed accurately.
What are are tips for avoiding common hospice election form denials?
- Tip 1: Use the model election form provided by CMS or stick to something very close to it. This will ensure that no critical elements are missed. CMS has provided a model hospice election form. Hospice agencies are not required to use this model form; they may design their own election form.
- Tip 2: Focus on the purpose of the document and stick with the required elements, Over the years, hospices have had a tendency to add to their election forms so that it has been moving away from its original legal intent. While it is good to provide patients with additional information, the election form may not be the appropriate place to provide this information. By adding information to the election statement, there is a risk that upon audit contractors may find fault with aspects of the document that are not part of Medicare’s required elements of the election statement. In other situations, contractors missed the election statement since it was buried in a such a long document.
- Tip 3: build in redundancy in the elements of the elements of the hospice election statement. Use the admission material to build in redundancy of the required elements of the hospice election statement. That is, the required elements can be included in the election statement but some of the election statements which, for example, are acknowledgement statements, can be included in other admission material that is provided to the patient on admission. This could be helpful to defend potential claim denials or invalid denials in case of audit.
- Tip 4: Reduce the possibility of errors in completing the forms, by stressing the importance of the forms, creating standardized processes, and leveraging technology. Reduce human error by ensuring that the individuals responsible for completing the documents understand their importance. Human error is the biggest problem with properly completing the hospice election statement form. Create processes to double check the forms – in real time. Leverage technology, where possible, to eliminate the possibility of errors or to detect errors.
Where can you find more information?
by editor | Oct 18, 2022 | Billing, Billing - General, Compliance and Regulatory - Directors, Hospice 101 - Aides, Hospice 101 - Chaplain, Hospice 101 - Office Team, Hospice 101 - Social Workers, Rules and Regulations - Chaplains, Rules and Regulations - Nurses, Rules and Regulations - Social Workers
To receive hospice services under the Medicare benefit, a patient or his authorized representative must elect hospice care.
If the patient or authorized representative elects to receive hospice care, the patient must file an election statement with a specific hospice agency. The election statement serves to indicate that the patient is choosing hospice care.
The election statement and the election statement addendum are conditions for payment.
What is the structure of a hospice election form?
Every hospice agency can design and create their own hospice election statement form although Medicare has published a model form that can be used by hospice agencies Model Hospice Election Statement. The election statement must include all of the following elements:
- Name of hospice agency that will be providing the services
- Acknowledge that nature of hospice services have been explained to the patient including, in particular, the palliative rather than curative nature of care
- Acknowledge patient understands that by electing hospice care, some Medicare services are waived
- For hospice elections beginning on or after October 1, 2020, a statement that although it would be rare, there could be some necessary items, drugs, or services that may not be covered by hospice because these items are deemed to be unrelated to the terminal illness or related conditions
- The effective date of the election. This may be the first day of hospice care of a later day. But it cannot be a date that precedes the date that the election statement was signed by the patient or their authorized representative.
- The individual who is serving as the patient’s attending physician, if any.
- Acknowledgement that the identified attending physician was the choice of the patient or authorized representative
- Signature of patient or authorized representative
There are some additional requirements for the election statements for elections beginning dated October 1, 2020 or later. These election statements must also include :
- Information on patient cost sharing for hospice services
- Notification of the patient or authorized representative right to receive an addendum to the election statement. The addendum is only required to be furnished to beneficiaries, their authorized representatives, non-hospice providers, or Medicare contractors who request this information. This addendum includes a list and rationale for the items, drugs, or services that are not covered by hospice services because the hospice has deemed these to be unrelated to the terminal illness and related conditions.
- Information on the Beneficiary and Family Centered Care Quality Improvement Organization (Beneficiary and Family Centered Care (BFCC) ), including that immediate advocacy is available through this organization if the patient disagrees with the hospice’s determination regarding non-covered services
Right to Request Patient Notification of Non-Covered Items, Services, And Drugs
At any time, a patient may request, in writing, the Patient Notification of Hospice Non-Covered Items, Services, and Drugs. addendum to the election statement.
The hospice agency must provide the notification within five days, if this request is made on the start of care date.
If the request is made during the course of hospice care, the hospice agency must provide the requested notification within 72 hours.
If the patient (or authorized representative) requests the addendum at the start of care but dies with five days, the hospice is deemed to have met its requirement and is not required to provide the addendum.
When would a hospice update the addendum?
The addendum lists the patient’s diagnoses and conditions that are present upon hospice admission and the items, services, and drugs that are not covered by the hospice because they are deemed to be unrelated to the terminal illness and related conditions.
During the course of hospice care, the addendum may require update, for example, if the patient’s plan of care is updated.
Changes to the addendum will need to be signed by the patient or his authorized representative and stored in the patient’s medical record with the hospice agency.
Where can you find more information on the election statement
