In a July 2011 report, the Office of Inspector General criticized the duplication of services that often results from the two entities’ overlapping care. The final rule emphasizes communication and coordination between the providers to avoid such duplication. Some provisions the agreement must address are:
- The services the hospice will provide
- The hospice’s responsibilities for determining the appropriate hospice plan of care
- The services the LTC facility will continue to provide
- A communication process to ensure residents’ needs are met 24 hours a day
LTC and hospice providers should act immediately to comply with this CoP by August 26, 2013. Failure to do so can result in sanctions. Delineating roles may result in challenging operational issues and require both providers to internally review what the best method is for offering patient care.
Lisa English Hinkle
McBrayer, McGinnis, Leslie & Kirkland, PLLC