Memphis Comfort Care Coalition Meetings
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June 2007 Meeting
The June MCCC community meeting will be held on Tuesday, June 3, from 5:30 - 7:30 P.M. at Trezevant Terrace. Chaplain Russell Belisle from Methodist Hospital, Germantown, will speak about the Congregational Health Network (CHN).
The CHN consists of congregations, healthcare institutions, civic organizations, government agencies and school that are woven together in relationships. The CHN strives to eliminate health disparity by stressing wellness and disease prevention, particularly obesity, diabetes, infant mortality and high blood pressure. When patients are discharged from the hospital, the CHN works to make a difference by ensuring that discharge planning includes all available community resources. Chaplain Belisle serves as chaplain/navigator for the CHN at Methodist Hospital, Germantown, where he assists pastors and congregation members during members' stays.
Trezevant Terrace is located at 177 N. Highland. Although Trezevant has a Highland address, the entrance is actually on Waynoka, which runs west off of Highland between Walnut Grove and Sam Cooper Boulevard. You turn west on Waynoka off of Highland, and the Trezevant entrance will be on your left. Our meeting will be held in the first floor Activities Room in the Trezevant Terrace. Tell the guard that you will be attending the Comfort Care meeting. After you are admitted to the grounds, follow the driveway around until you reach the parking area, which is now directly in front of the new assisted living building, the Terrace. When you enter the Terrace, turn right, and the Activities Room is the second room on the right. As usual, the meeting will be a potluck. If you plan to bring food, please e-mail Emily at efoxhill@aol.com or call 626-4233 to let her know what you will bring. Trezevant will supply bread, salad, tea, and coffee.
About the speaker: Chaplain Russell Belisle moved from Chicago to Memphis in July of 2002 in order to pastor Amazing Grace Lutheran Church, an intentionally racially diverse congregation. Previous to moving to Memphis, he pastored St. John Lutheran Church of Forest Park, Il, and St. Philip Lutheran Church of the South side of Chicago. While in Chicago, he took part in anti-drug rallies, feeding program, and homeless ministries. He has extensive training urban ministry, new mission starts, and racially diverse ministry. Before his involvement in congregational ministry, chaplain Belisle taught P.E., history, and religion at Lutheran high schools in Los Angeles and Indiana. Currently, he is serving at Methodist Germantown Hospital as a chaplain/navigator for the Congregational Health Network. His hobbies include reading, travel, and visiting old car museums. He is married to Dr. Jodice Belisle and they have one, soon to be 13 year old, child, Rachel.
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University of Memphis Continuing Education Classes on Advance Care Planning: Dealing with end-of-life care is a difficult but necessary thing for all of us to do, regardless of our current age or health. Without an advance care plan, someone other than you (including the courts) may be making decisions about your life. Wouldn't you rather make those decisions yourself, while you can? Take a few hours to learn about what Advance Care Planning is and why it is important; what our laws allow you to do; and the myriad issues that must be considered when making an advance care plan, including treatment issues, organ donation, and quality of life. Don't leave these decisions to chance. Take charge of your future. Class fee includes all forms and materials.
Course #: PHC04301SU
Schedule: Tues., 6/10/08
Hours: 6:00 P.M. - 9:00 P.M.
Location: University of Memphis Main Campus
CEU's Earned: 0.3
Fee: $34
Register at: http://registration.xenegrade.com/umce/courseDisplay.cfm?schID=497
Course#: PHC04302SU
Schedule: Tues., 7/8/08
Hours: 6:00 P.M. - 9:00 P.M.
Location: University of Memphis Main Campus
CEU's Earned: 0.3
Fee: $34
Regiser at: http://registration.xenegrade.com/umce/courseDisplay.cfm?schID=501
Instructor Jane Owen has over 30 years experience in critical care, oncology, occupational health and family practice as a Nurse Practitioner. She is currently a certified Palliative Nurse Practitioner at Methodist University Hospital; and a founding and current board member on the Mid-South Comfort Care Coalition and the Mid-South Biomedical Ethics Center. Owen is also active at the state level as the West Tennessee region representative on the TN End of Life Partnership (TELP). It is because of this representation that she was able to be involved in helping to write the TN Health Care Decision's Act of 2004.
These two classes are listed under Health and Wellness in the University of Memphis online Professional and Continuing Education Catalog. The entire catalog may be accessed at http://umce.memphis.edu/ For assistance with registration call 901-678-6000.
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News from the National Hospice and Palliative Care Organization
As a Caring Connections partner, the Comfort Care Coalition receives regular updates from the National Hospice and Palliative Care Organization. Two issues on which we have received recent NHPCO updates are a) the publication of the new Medicare Hospice Conditions of Participation and b) a Federal proposal that would cut Medicare hospice payments by $2.29 billion over five years. This information is, of course, not new to Comfort Care Coalition’s partnering hospices and their employees. However, Comfort Care Coalition members who are not affiliated with the hospice community may be interested the information in these updates, which is first summarized and then reproduced below:
a) The general consensus of the NHPCO Regulatory Committee is that the new Medicare Hospice Conditions of Participation are a significant improvement over the proposed CoPs and that CMS paid close attention to comments from the industry and responded in a very positive manner. In the words of one hospice provider today, "I found the new CoPs an amazing surprise, so responsive to our concerns and positive toward hospice. The new CoPs position hospice for a positive future....."
b) On April 28, 2008, the Department of Health and Human Services CMS issued a Notice of Proposed Rulemaking (NPRM) for an adjustment in the FY2009 Hospice Wage Index. According to NHPCO, this proposal would cut Medicare hospice payments by $2.29 billion over five years and will be implemented administratively, thus bypassing Congressional approval. Without immediate Congressional intervention, this proposal will be implemented as early as August 1, 2008.
It is difficult to understand how these two very different Medicare initiatives will mesh. For those who are interested, a cut-and-paste of two NHPCO e-mails covering each of these issues is included below:
NHPCO Regulatory Alert:
Information and Assessment on NPRM Issued by CMS
To: NHPCO Membership
From: NHPCO Regulatory Team
Date: April 30, 2008
Summary: On April 28, 2009, CMS issued a Notice of Proposed Rulemaking (NPRM) for an adjustment in the FY2009 Hospice Wage Index. Specifically the proposed rule would phase out the Medicare budget neutrality adjustment factor (BNAF) and clarify two wage index issues, pertaining to the definition of rural and urban areas and the use of multi-campus hospital facilities.
* Chart showing impact of year one (PDF)
* NHPCO response to the proposed rule (04/29/08)
History: The hospice wage index was originally adjusted in 1995, when a Negotiated Rulemaking Committee was appointed to address the inaccuracies in the original hospice wage index, account better for disparities from one geographic location to another and develop a wage index that would be as accurate, reliable and equitable as possible. At that time, the committee agreed to implement a special adjustment (BNAF) to ensure payments in the aggregate are budget neutral to payments using the original 1983 hospice wage index. The adjustment is still in place today and results in providers currently receiving about 4 percent more in payments than they would receive in the adjustment fact were not applied.
What does budget neutrality mean? Budget neutrality means that in a given year, estimated aggregate payments for Medicare hospice services using the updated hospital wage index values will equal estimated payments that would have been made for these services if the 1983 hospice wage index values had remained in effect, after adjusting the payment rates for inflation. In other words, the BNAF provided an increase in hospice rates each year. The impact in FY1998 was an increase of approximately 2%. CMS reports that by FY2008, the BNAF had increased so that rates were an average of 4% higher.
What does the proposed rule do? CMS is proposing a three year phase out of the BNAF beginning in FY2009, effective October 1, 2008. The proposed rule sets out the following schedule for the phase out:
FY2009: Reduce the BNAF by 25%
FY2010: Reduce the BNAF by an additional 50%
FY2011: Complete elimination of the BNAF
CMS states that this first year of implementation would "only" reduce rates by an average of 1.1%. In some parts of the country, the reduction in rates this first year is significantly greater, with a reduction in some areas of between 5 and 10%.
Charts showing impact: NHPCO is creating charts that will provide detail for each county in every state and the percent change from the FY2008 wage index published last summer:
* Chart showing impact of year one (PDF)
The two following documents are being prepared by NHPCO staff and will be released
tomorrow:
* Chart showing impact over three years (PDF)
* Wage Index Calculator for FY09
Summary of impact on hospice providers: NHPCO has analyzed the impact of the first year of the proposed rule on counties throughout the country. Final implementation of the phase in could produce dramatically worse impacts within the hospice community.
In the first year of implementation:
* 80.8% of counties would have their wage index decreased and 3.4% of counties would have their wage index decreased by 5% or more.
* 165 (5.1%) counties would have no change to their wage index.
* 14.1% counties would have their wage index increased, including 1.9% counties who would have their wage index increased by 5% or more.
What you can do? CMS has issued this as a proposed rule, with a 60 day comment period. Comments are due back to CMS by June 28, 2008. NHPCO will be preparing a comment letter and would encourage members to respond as well, through state organizations and as individual providers to see how the proposed rule impacts care and services. Watch the NHPCO Web site at www.nhpco.org/regulatoryf or talking points and further analysis.
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NHPCO Regulatory Reviews Significant Points of New Medicare Conditions of Participation
To: NHPCO Membership
From: NHPCO Regulatory Team
Date: May 28, 2008
The final Medicare Hospice Conditions of Participation posted on the Federal Register public inspection page and on the CMS Web site on Tuesday, May 27. (See NHPCO's Regulatory Alert of 05/27/08.) The official Federal Register publication of the final rule is scheduled for June 5, 2008. If the final regulations publish as planned, the effective date will be 180 days after publication, or December 2, 2008.
The NHPCO Regulatory Committee assembled in Alexandria, VA on May 27-28 upon the release of the COPs to analyze the final rule, identify changes from the proposed rule, and prepare resources for providers to aid in implementation. The NHPCO Regulatory Committee would like to share some of the highlights of the final rule, by section and our beginning thoughts. The committee will continue to do detailed analyses in preparation for training and resource materials to be available to NHPCO members.
The general consensus of the NHPCO Regulatory Committee is that the new Medicare Hospice Conditions of Participation are a significant improvement over the proposed CoPs and that CMS paid close attention to comments from the industry and responded in a very positive manner. In the words of one hospice provider today, "I found the new CoPs an amazing surprise, so responsive to our concerns and positive toward hospice.The new CoPs position hospice for a positive future....."
Effective Date: Expected to be December 2, 2008.
What does the effective date mean? The current (soon to be old) Conditions of Participation will be in effect until the effective date of the new final COPs. In other words, begin planning for the implementation of new COPs, but do not make changes now that would bring your hospice out of compliance with current COPs until the effective date.
Definitions
Bereavement counseling: Added clarification that bereavement counseling can be provided both before and after the patient's death, with the expectation that it must begin before death.
Dietary counseling: Dietary counseling may be done by a registered nurse in addition to a dietician or nutritionist.
Initial assessment: A new definition which clarifies that the purpose is to determine the patient's immediate support needs.
Representative: More specifics were added to the definition, including who can sign for the patient. The definition also defers to state law.
§418.52 Patient Rights
* Deleted the need to address patient liability during the initial assessment.
* A signature is required that the patient received a copy of the patient's
rights document rather than having to show understanding.
* Deleted the need to review the agency's drug policies during the initial
assessment.
§418.54 Initial and Comprehensive Assessment:
* Initial assessment: When the COPs are effective, the registered nurse will
have 48 hours after the patient elects hospice care to complete the initial
assessment, an increase from the 24 hours in the proposed COPs.
* Comprehensive assessment: The proposed COPs recommended 4 days to complete
the comprehensive assessment. The final rule allows 5 days to complete the
comprehensive assessment.
* The comprehensive assessment process is driven by the hospice's own policies
and procedures.
* The IDG completes the comprehensive assessment. The specific disciplines
involved may be determined by the needs identified in the initial assessment.
* Reassessment and review of plan of care: The proposed COPs recommended reassessment
and review of plan of care every 14 days. The final rule allows 15 days to
reassess and review the plan of care.
* Check your forms for data to be collected during the comprehensive assessment
and to be used for performance improvement.
§418.58 Quality Assessment/Performance Improvement (QAPI):
* Governing body must designate someone to direct the QAPI program. The final
rule no longer requires that the medical director direct the QAPI program.
* The final rule allows 240 days (an extra 60 days beyond the 180 day implementation
period) for a hospice to collect data in order to conduct performance improvement
projects.
§418.60 Infection Control
* Hospices will be required to have an infection control policy and procedure.
§418.76 Hospice Aide Services
* In the final rule, the discipline is designated as hospice aide.
* Hospice aide provides services that are ordered by the IDG.
* No less than every 14 days, the RN must make an on-site visit to the patient's
home to assess the quality and services of the hospice aide. If an area of
concern is noted, the hospice must make an on-site visit while the aide is
performing the care.
* The hospice nurse must make an annual on-site visit to a location where the
patient is receiving care in order to observe and assess each aide as he or
she is performing care.
§418.106 Drugs and Biologicals, Medical Supplies and Durable Medical Equipment
* Interdisciplinary group must confer with an employee or contracted individual
with education and training in drug management to ensure that drugs and biologicals
meet each patient's needs. The definition of the profession of the individual
and the education and training required is not defined.
* The pharmacist services for a hospice that provides inpatient care directly
in its own facility must include evaluation of a patient's response to medication
therapy, identification of potential adverse drug reactions and recommended
appropriate corrective action.
* Nurse practitioners can order medications in accordance with applicable state
law.
§418.108 Inpatient Care
* When the COPs become effective, RN will not required to be on site and
providing direct patient care 24 hours per day for inpatient respite.
* RNis still required for the provision of general inpatient care.
* When a hospice is providing inpatient care directly, CMS has added significant
direction to hospice providers regarding the use of restraints and seclusion,
emphasizing the intent and effect of the intervention. This is an effort to
be consistent with other healthcare environments.
§418.112 Nursing Homes
* New condition level requirements for care provided in nursing homes.
* There are additional language requirements to be included in the written
agreement, necessitating significant amendments to existing contracts.
* RN 24 hours/day is not required for respite care provided in a nursing home.
§418.114 Personnel Qualifications
* Social Worker
o MSW remains the ideal.
o Can use:
+ BSW
+ BA/BS in Psychology, Sociology or related fields with one year's experience
in health-care if supervised by MSW.
o BSWs employed prior to the COP implementation date do not need MSW supervision.
§418.114 (c) (3) Criminal Background Checks
* Is required for staff with direct patient contact or access to clinical
or financial records.
* Staff includes paid, contract and volunteer staff.
* If the state has a background check requirement for a discipline, those requirements
must be met, even if they are less stringent than the federal requirement.
* If no state requirement, then federal requirements must be met.
Watch the NHPCO Web site at www.nhpco.org/regulatory as the NHPCO Regulatory Committee develops training materials and resources for NHPCO members. Questions may be directed to regulatory@nhpco.org.