DOI: 10.1097/01.NHH.0000356823.40551.ce

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PMID: 19509517

Issn Print: 0884-741X

Publication Date: 2009/06/01


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The New Hospice Interpretive Guidelines: Are Hospice Providers Compliant?

JENNIFER KENNEDY

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Excerpt

December 2, 2008 marked the historic implementation date of the new Medicare Hospice Conditions of Participation (CoPs). The companion interpretive guidelines to the CoPs were anxiously awaited by the hospice industry and the Centers for Medicare and Medicaid Services (CMS) utilized draft interim interpretive guidelines on November18, 2008 as the first surveyors were being trained on the new CoPs and interpretive guidelines. CMS received feedback from surveyors on the interim edition of the interpretive guidelines, made clarifying changes, and released the final interim interpretive guidelines on January 2, 2009.
The hospice interpretive guidelines are the guidelines a state/federal surveyor use to assess the compliance of a hospice provider with the Medicare hospice conditions of participation. The guidelines provide surveyors with probe questions and additional guidance for assessing compliance with each regulation. By reviewing the interpretive guidelines, hospice providers have the benefit of knowing what the focus of the surveyor will be in advance of a certification or recertification survey. Beginning December 2, 2008, CMS and state survey agencies were within their parameters to survey hospices under the new CoPs, but CMS Survey and Certification Group were given direction not to begin surveys until the hospice interpretive guidelines were officially published. Now that hospice providers have the new hospice interpretive guidelines, how should they use them to become survey ready and what “hot spots” should be targeted? This article will discuss those “hot spots”, and what the surveyor will look for in a compliant hospice program.
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