COP update

Just wanted to update you on my reading and digesting of the COPs. I didn't find near the amount of free time over the weekend as I wanted, so I have not finished the 55 page document yet. I'm scheduled to sit through some Continuing Education seminars by tape over the next week or so, and figured I'd study the details of the proposed COPs then.

At this point, I feel a real vindication of how my company has been doing business. Most of the new rules are to make hospices do what we have been doing all along. There are a few things that we'll have to change, but they are not bad changes.

I do think some of the changes are going to be very hard on small hospices and somewhere near impossible for small rural hospices that cover hundreds of miles of territory. I'm not sure that the provision that each patient must be seen by a nurse, social worker, and chaplain within four calendar days of admission is possible or practical for some of those small rural hospices. If you admit on Thursday (which often includes the exhausting ordeal of the pt. being discharged from the hospital and driven home) and the RN assesses that day, then you only have three days left to get the social worker and chaplain in the door. If the part time Social Worker or Chaplain is already booked for Friday, then they are going to have to assess the patient over the weekend (something that is not easy for part-time Chaplains who often pastor small churches). There are not many part time employees who want to work weekends. These people are hard enough to find; this regulation would make it harder.

Again, I'll give more thoughts as I continue to read, but I've kind of put it on the back burner because it is something that I can do while getting CE stuff out of the way.

I'd also like to say that I was probably a bit harsh in my criticism of NHPCO last week. It would have been very helpful for them to have put out a statement about the changes that are being proposed (something they still have not done), but they have to make sure they understand these issues before they give an opinion. That takes time, so I shouldn't have expected much from that so quickly. They have obviously been very involved in helping Medicare craft these proposed changes, because it seems that every page mentions one of NHPCO's programs. I guess that means that if these COPs end up being bad for the hospice movement NHPCO will have shown itself to be worthless at best. I look forward to learning their response. Again, I shouldn't have spoken out against them so quickly.