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.
Outcome Resources offers an optional Medication Review service that meets these requirements to keep your hospice compliant.
A detailed pharmacist report with specific, individual recommendations is prepared and promptly e-mailed or faxed directly to a key individual that you designate. Turnaround time is typically fewer than 48 hours -- well within the five-day time frame established by Medicare’s Conditions of Participation.
This report meets or exceeds all requirements specified within the Hospice CoP and can be included in your patient’s records, or printed out and shared at an interdisciplinary group meeting.
Download a Sample Review Below
| BarbaraJuly 10, 2011The last rally has been seen with very sick, terminally ill paetints, as well as with less sick, elderly. Take the opportunity, whether the last rally or the beginning of a new continuing phase to her life, to renew your awareness and appreciation for every single day, and don't take even one for granted. My mother rallied for two days, and we thought she was out of the woods , then she suddenly began the dying process when vomiting started, as I tucked her into bed the night of the second day. It had been a terrific day, and the sudden onset of the dying process was a shock, after two days of renewed hope and optimism. I am so very thankful for those two days, when family came to see her, and they shared old stories and photo albums and she smiled more than she had in a long time. Don't be heartbroken, if your mom is in the rally and it ends abrubtly. Hopefully that won't be the case. At least, you know that you gave her the best that you could by keeping her home, where she wanted to be. That will help you to not have regrets, later, which are sometimes hard to ward off, no matter how hard we try to be the best caregivers we can be.
Posted 2/14/2013 09:58:44 AM
|Directors for Kenia Nakuru, Kenya > Directors for Kenia Looking for a volunteer maaemngent opportunity? The International Humanity Foundation needs your expertise and vigour to direct our orphanage! The International Humanity Found Learn more here: I'm more insecure than confidentI'm more Coke than water with lemonI'm more blessed than cursedI'm more chocolate than vanillaI'm more Jack than SawyerI'm more clumsy than gracefulI'm more Brady Bunch than Partridge FamilyI'm more The Office than anything else on TVI'm more blog commenter than blog stalker]]>
Posted 8/7/2012 10:52:17 PM
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Education Resources and Support for Hospices
Stay up-to-date on the latest hospice pharmacy benefits management information and tools with a variety of education resources and support at no extra charge. We offer presentations live at your facility, over the Internet or viateleconference, online service education programs, customized courses, and courses accredited for nursing continuing education credit.
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