Medication Reviews and Medicare CoPs: Is Your Hospice in Compliance?
Posted by Dr. Julia Harder
The Medicare hospice Conditions of Participation (CoPs) are the federal regulations that govern all Medicare-certified hospice programs, and contain the health and safety requirements that all hospices are required to meet. In section 418.54, the CoPs specify standards for a “comprehensive assessment” that must be conducted by the hospice interdisciplinary group (IDG). The comprehensive assessment must take into consideration, among other things, the patient’s medication profile, including “a review of all of the patient's prescription and over-the-counter drugs, herbal remedies and other alternative treatments that could affect drug therapy.” There are three main requirements related to the medication review process that hospices should be aware of. According to the Center for Medicare and Medicaid Services (CMS), these requirements comprise three of the top 10 most frequent survey deficiencies cited during Medicare hospice recertification surveys.
1. The CoPs specify that the hospice IDG “must complete the comprehensive assessment no later than 5 calendar days after the election of hospice care” (which is the effective date of the election statement).
2. The drug profile review should include (but is not limited to) an analysis of:
a. Effectiveness of drug therapy.
b. Drug side effects.
c. Actual or potential drug interactions.
d. Duplicate drug therapy.
e. Drug therapy currently associated with laboratory monitoring.
The medication review should be completed by an individual with education and training in drug management, such as a pharmacist or physician.
3. The CoPs require that the hospice IDG periodically update the comprehensive assessment “as frequently as the condition of the patient requires, but no less frequently than every 15 days.” Note that the requirement is that the comprehensive assessment be updated, not completely redone. Here, the language is open to interpretation. According to the CMS Interpretive Guidelines (used by surveyors assessing compliance), “The hospice should review each patient’s medications and monitor for medication effectiveness, actual or potential medication-related effects, duplicate drug therapy and untoward interactions during each update to the comprehensive assessment, and as needed as new medications are added or changed, or the patient’s condition changes. Hospices are not required to complete, in full, those documents that they identified as comprising their comprehensive assessment every 15 days, although hospices are free to do so if they so choose. They are required to identify and document if there were no changes in the patient/family condition or needs.” Some hospices choose to have a new medication review performed every 15 days regardless of whether there have been any major changes to the patient’s medication profile or clinical status. Other hospices choose to only perform a new medication review when it is warranted by major changes. Either system would be considered compliant with CoPs.
With all the CoPs, a crucial element is documentation. All assessments should be clearly documented and accessible within the patient’s record.