A Guide to Maintaining Hospice Conditions of Participation Compliance

Maintaining hospice compliance with the Conditions of Participation (CoPs) is vital for agencies to deliver top-notch hospice care and remain eligible for reimbursement from Medicare and Medicaid. With the rapidly evolving world of hospice care, staying current on industry changes and regulations is difficult while clinicians dedicate focus to delivering essential, quality, end-of-life care. Understanding the best practices to maintain compliance is essential for hospice agencies to survive the countless nuances and challenges.  

The Importance of CoP Compliance  

Hospice compliance is crucial for maintaining quality patient care and agency integrity. Compliance plays an essential role across all facets of operation, especially within CoP regulation. CoPs are health and safety regulations all hospices must meet, set to ensure the quality and protection of patients regulated by the Centers for Medicare & Medicaid Services (CMS). Organizations must also meet these conditions to begin and continue participating in Medicare and Medicaid programs, per CMS regulations.¹ Remaining compliant with CMS regulations provides favorable reimbursement and support for the agency and enhances end-of-life care for the patient and the family.    

Best Practices for Maintaining Compliance   

Navigating the ever-changing landscape of hospice care regulations presents an ongoing challenge for the industry. Compliance includes both the understanding of regulations and incorporating preemptive measures throughout an agency, including:   

1. Remaining up to date on regulations and industry advances  

Staying on top of industry regulations, laws, and technological advances is essential for a hospice industry to avoid scrutiny or violation of regulations. Ensuring your agency follows CMS regulation notices is critical to remaining compliant; regularly check CMS regulation updates and stay informed about local, state, and federal laws that can influence hospice care. Technology is also continuously advancing in ways that can help alleviate hospice compliance issues by providing smoother care transitions, ease of communication, and much more. Staying on top of quickly changing industry changes will help reduce the risk of compliance violations in the future.   

2. Keeping employees current and trained   

In addition to staying informed about industry advancements and regulations, it is essential to disseminate this information to current and future employees effectively.  To achieve this, agencies need to actively engage in staff training, internal communication efforts, compliance testing and check-ins, and internal audits. Ensuring that employees adhere to industry regulations and standards and understand the consequences of non-compliant actions should remain top of mind. Implementing a compliance program helps an organization adhere to laws, regulations, and industry standards.  These measures play a crucial role in promoting ethical practices and upholding patient rights, preventing fraud and abuse, and safeguarding the integrity of the organization.²  

3. Documentation and record-keeping   

Agencies must maintain accurate and thorough records of all patient history, including patient assessments, care plans, and other relevant documents. Keeping a detailed record of patients ensures compliance and results in a higher quality of care through detailed examinations, patient understanding, observational skills, and internal communication. Documentation also promotes external communication efforts by assisting the patient's family through end-of-life care. With the increased use of electronic health records (ERH), documentation is more accessible and reduces potential risks for fraud, waste, abuse, and improper payments.³ 

4. Quality Assessment Performance Improvement (QAPI)  

QAPI helps hospice providers implement and maintain their quality improvement programs and activities.⁴ The organization's QAPI program should be continuously monitored to ensure robust prevention strategies exist to promote high quality care. QAPI and compliance programs work together to fill organizational gaps and require program collaboration to reach intended success.    

Benefits of Remaining Compliant   

Adhering to the hospice Conditions of Participation helps patient and agency reimbursement while increasing reliability and trust within the hospice community. Implementing compliance control puts patients' rights, regulations, and staff training as a top priority, which leads to improved outcomes and reputation. Developing a culture that prioritizes compliance is also crucial for a positive revenue stream. Remaining compliant with CoPs helps hospice agencies achieve their main goal of providing quality care and satisfaction for the patient and family.   

Compliance Assistance with Maxwell

Understanding and implementing CoP compliance strategies and procedures is crucial for the survival of quality hospice organizations. However, with the ever-evolving nature of programs, technology, and the entire industry, adhering to compliance requirements presents additional challenges to the already extensive list. Implementing compliance programs can help reduce future issues while the focus remains on quality, patient care. Maxwell’s leading experts help guide agencies through industry challenges by providing strategic support and tech-enabled solutions that work to ensure both patient and agency satisfaction.

 
This blog was originally published as "A Guide to Maintaining Hospice Conditions of Participation Compliance" by Maxwell Healthcare Associates on 5/7/24, for Maxwell Healthcare Associates. The Maxwell TEC editorial team has since updated this article to ensure accuracy and relevance. 

Resources

1. Conditions for Coverage (CfCs) & Conditions of Participation (CoPs) | CMS  

2. CHAP-CompDocs_HSP-Strategies-for-Success_Interactive.pdf (chapinc.org)  

3. A Compliance Program for Electronic Health Records Fact Sheet (cms.gov)  

4. QAPI-Toolkit.pdf (nhpco.org)