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Hospice Conditions of Participation – employees versus contractors

Hospice conditions of participation require that almost all hospice core services are delivered by hospice agency employees and may not be delivered by contractors. Hospice core services include: 

  • Nursing services
  • Social services
  • Counseling services including spiritual, bereavement and dietary
  • Physician services

Although physician services are a core service, the regulations permit a hospice agency to contract for physician services. 

When may a hospice use contracted staff for core services?

Other than physician services, only under extraordinary circumstances may a hospice agency use contracted staff for core services.  

What are extraordinary circumstances?

Under extraordinary circumstances, a hospice may use contracted staff to provide core services. Examples include:

Patient needs unexpectedly exceed the capacity of hospice agency employees, due to unanticipated surge in demand.  In this case, contracted staff may be temporarily used to service patients.

Temporary staffing shortages, for example due to illness, result in the inability of the hospice to service patient needs. In this case contracted staff may be used to temporarily supplement hospice agency employees.  

A hospice patient travels outside of the hospice agency’s service area. In this case the agency is permitted to contract with another Medicare certified hospice agency to provide services to the patient while the patient is traveling.

Where can you find more information?

See the regulations here: Regulations – employees vs contractors