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Spotlight on the Hospice Special Focus Program

was created by the to identify and monitor poor hospice performers. Hospices selected for the SFP will face increased oversight from CMS and potential termination from the Medicare program if no improvement is made while in the program.

To help hospice providers navigate and understand this new regulatory landscape, ̲app created a one-page reference guide to highlight key points in the SFP and the ramifications for hospices selected to participate in the program.

Zaundra Ellis, Vice President of Hospice Professional Services at ̲app, created the guide and breaks down what providers can expect from the SFP.

Quality Measures

Ellis states that CMS will be looking at performance data from hospices over the last three years to determine inclusion in the SFP. An algorithm will be created from elements of the , including the and elements of the , along with survey results. Condition-level deficiencies, drawn from selected measures from the will be also considered by CMS.

“The condition-level deficiency is cited when all of the standards that make up that condition of participation, either a majority or all of them, are not met,” Ellis says. “Some of these organizations are not able to meet all the standards.”

Aside from survey results, substantiated complaints will also be weighed heavily by CMS.

“If someone complains and they come and investigate that complaint, and the surveyor then finds out that there was a compliance issue tied to that complaint, that’s a substantiated complaint, so they’re looking those over three years as well.” Ellis says.

Based on these elements, a final score will be created for each hospice. A high score in this instance indicates poor quality. Providers with the highest scores will be selected for the program. CMS will notify selected providers later this year.

Medicare Termination

Hospices selected for the SFP will be surveyed every six months and their progress will be reported on the SFP website, Ellis outlines in the guide. Hospices who fail to complete the program by returning to standard compliance will face potential termination from the Medicare program.

“Organizations that do not graduate from the program are at risk of having their Medicare certification pulled,” Ellis says. “So let’s say an organization gets a condition-level deficiency for plan of care and patient rights, they’re going to stay in the program for another six months, then they get tagged again for patient rights. At that point, [CMS] starts the process of penalties, CMS taking over management of the organization and ultimately losing their Medicare certification.”

Ellis shares that organizations selected for the program will have to go a year without any condition-level deficiencies to graduate from the program.

Hospice Preparation

While CMS has the best intention in creating the SFP and monitoring poorly performing hospices, Ellis shares, one thing the program lacks is supportive training for providers.

She advises hospices to prepare for the increased oversight by staying up on top of for any regulatory changes, looking over survey results from the last three years, focusing on your Quality Assurance and Performance Improvement (QAPI) program and investing in training and certification.

̲app Training and Certification+ will have everything a hospice would need to learn how to properly care for and document care for their patients to get out of the [Hospice] Special Focus Program.” Ellis says.

She also encourages providers to reach out to hospice consultants and accrediting bodies, like the and the for support and education.

“Having a lot of grit to work through a process where there really is no guidance and being a sponge, learning as much as possible about hospice compliance is going to be key.” Ellis says.

To download Ellis’ guide on the Hospice Special Focus Program, click here.

̲app Hospice, a cloud-based hospice software, includes simple tools such as real-time plan of care updates to help keep organizations compliant.


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