Hospice COPs - is your hospice compliant?

I've been going over my checklists for compliance for my hospice's implementation of the new Medicare Hospice Conditions of Participation for the thousandth time, and was wondering how many hospices across the nation are not 100% compliant at this point.

The new COPs went into effect on December 2nd, and my hospice was not ready. We're nearing a month later, and my hospice is still not 100% compliant. Where are those nursing home and and DME contracts we mailed out? How many layers of bureaucracy can any one contract have to go through before someone can sign it?

I'm guessing that I'm not near alone. There are regulations in the new COPs that are hard to accomplish (especially for small hospices). There are also some that nobody seems to fully understand. I don't think Medicare even understands what they want us to do for some of them. I have spent the last six months putting things in place, but have been dragging my feet on a couple of issues hoping that Medicare would clarify what, exactly, they want us to do. Those clarifications have not come. Clearly, we can't wait forever. My waiting game has made my hospice knowingly non-compliant for the first time ever. Nothing big. Nothing that effects patient care. Just details that are not totally in place.

How about you?

Journal of Palliative Medicine is free this month

Thanks to the brains at Pallimed for pointing out that the Journal of Palliative Medicine is free online through the end of the year. You can check out every edition ever published, so jump in, dig in, and learn all you can over the next few weeks.

NHPCO Rate Cut Lawsuit Dismissed

The lawsuit filed against Medicare by the National Hospice and Palliative Care Organization has been dismissed. As I understand it, the case was dismissed without any comment on the actual claims of the case, because the judge felt like hospice providers should appeal Medicare's decision directly (through an internal Medicare appeals process) before the lawsuit should be considered. You can read the NHPCO press release yourself.

In the meantime, the rate cut has taken effect and we continue to care for patients with less money than we would have had if Medicare would have done nothing. Not sure what the next step is, but I'm hoping the fight isn't over. Will President Obama and the Democrat majority come to our rescue? Guess we'll find out early next year.