HOSPICE CONTRACTING CHECKLIST FOR INPATIENT …

1 HOSPICE CONTRACTING CHECKLIST FOR INPATIENT SERVICES, RESPITE CARE AND VENDOR AGREEMENTS. The following CHECKLIST can be used to verify that the regulatory requirements are addressed in HOSPICE contracts for INPATIENT services, respite care, and vendor services. This CHECKLIST is separated into three categories: (1) General HOSPICE obligations for all types of HOSPICE contracts; (2) Specific obligations for INPATIENT services and respite care agreements; and (3) Specific HOSPICE regulatory obligations related to a variety of vendor contracts. In each part of the CHECKLIST , the obligations with asterisks are required by regulation to be included in the applicable agreement. GENERAL HOSPICE OBLIGATIONS. OBLIGATION & CITATION BRIEF DESCRIPTION. *Authorization by HOSPICE Services must be authorized by the HOSPICE .

2 42 (e). *Safe and Effective Services Services must be furnished in a safe and effective manner by qualified personnel. 42 (e). *Plan of Care Services must be delivered in accordance with the patient's plan of care. 42 (e). *Criminal Background Checks HOSPICE contracts must require that all contracted entities obtain criminal background checks on contracted employees who 42 (d) have direct patient contact or access to patient records. *Inspection of Records by The provider shall make available until the expiration of five years from the termination of the agreement, upon written request, Government to the Secretary of Health and Human Services, and upon request, to the Comptroller General of the United States, or any of 42 their duly authorized representatives, the agreement and any of the provider's books, documents, and records that are necessary to certify the nature and costs of Medicare reimbursable services provided under the agreement.

3 If and to the extent the provider carries out any of its duties under this agreement through a subcontract with a related organization having a value or cost of $10,000 or more over a 12-month period, the provider shall ensure the subcontract contains a clause comparable to the clause above. Professional Management The HOSPICE must retain administrative and financial management and oversight of staff and services for all arranged services, Responsibility to ensure the provision of quality care. 42 (e). QAPI The HOSPICE 's quality assessment and performance improvement program (QAPI) must involve all HOSPICE services, including 42 those services furnished under contract. * Obligations with asterisks are specifically required by regulation to be included in the written agreement.

4 2014 All Rights Reserved Reinhart Boerner Van Deuren Prepared by Reinhart HOSPICE and Palliative Care Practice Group, Meg Pekarske, chair GENERAL HOSPICE OBLIGATIONS. OBLIGATION & CITATION BRIEF DESCRIPTION. Training The HOSPICE must provide orientation about the HOSPICE philosophy to all contracted staff who have patient and family 42 (g); (c) contact. The HOSPICE must assess the skills and competence of all individuals furnishing care and, as necessary, provide in-service training and education programs where required. The HOSPICE must have written policies and procedures describing methods of assessment of competency. The HOSPICE must provide infection control education to contracted providers. Coordinating Care The HOSPICE must develop and maintain a system of communication and integration to either: 42 (e) ensure that the IDG maintains responsibility for directing, coordinating, and supervising the care and services provided.

5 Ensure that the care and services are provided in accordance with the plan of care;. ensure that the care and services provided are based on all assessments of the patient and family needs; and provide for and ensure the ongoing sharing of information between all disciplines providing care and services in all settings, whether the care and services are provided directly or under arrangement. Availability of Services Nursing services, physician services, and drugs and biologicals must be made routinely available on a 24-hour basis, 7 days per 42 (c)(2) week. Other covered services must be available on a 24-hour basis when reasonable and necessary to meet the needs of the patient and family. Licensed Professional Services Licensed professionals must actively participate in the coordination of all aspects of the patient's HOSPICE care, in 42 accordance with current professional standards and practice, including participating in ongoing interdisciplinary comprehensive assessments, developing and evaluating the plan of care, and contributing to patient and family counseling and education.

6 Licensed professionals must participate in the HOSPICE 's quality assessment and performance improvement program and HOSPICE sponsored in-service training. Specific training requirements, duties, and supervision requirements for individuals providing these services are also addressed in 42 Method for Criminal Criminal background checks must be obtained in accordance with state requirements. If there are no state requirements, Background Checks criminal background checks must be obtained within three months of the date of employment for all states in which the 42 (d) individual has lived or worked in the past three years. * Obligations with asterisks are specifically required by regulation to be included in the written agreement. 2014 All Rights Reserved Reinhart Boerner Van Deuren Prepared by Reinhart HOSPICE and Palliative Care Practice Group, Meg Pekarske, chair GENERAL HOSPICE OBLIGATIONS.

7 OBLIGATION & CITATION BRIEF DESCRIPTION. Standards of Practice Services must be provided in a manner consistent with current standards of practice. 42 General Personnel Qualifications All professionals who furnish services directly, under an individual contract, or under arrangements with a HOSPICE , must be 42 (a); legally authorized (licensed, certified, or registered) in accordance with applicable federal, state, and local laws, and must (c) act only within the scope of his or her state license, or state certification, or registration. All personnel qualifications must be kept current at all times. Compliance with Laws Staff must operate and furnish services in compliance with all applicable federal, state, and local laws and regulations related 42 to the health and safety of patients .

8 Patient Grievances The HOSPICE must be notified of patient grievances regarding treatment or care that is (or fails to be) furnished and the lack of 42 (b)(1)(iii) respect for property by anyone who is furnishing services on behalf of the HOSPICE . Caregiver Misconduct The HOSPICE must be notified of all alleged violations involving mistreatment, neglect or verbal, mental, sexual, and physical 42 (b)(4) abuse, including injuries of unknown source, and misappropriation of patient property by anyone furnishing services on behalf of the HOSPICE . * Obligations with asterisks are specifically required by regulation to be included in the written agreement. 2014 All Rights Reserved Reinhart Boerner Van Deuren Prepared by Reinhart HOSPICE and Palliative Care Practice Group, Meg Pekarske, chair INPATIENT SERVICES CONTRACTS.

9 OBLIGATION & CITATION BRIEF DESCRIPTION. INPATIENT Care for Symptom INPATIENT care for pain control and symptom management must be provided in (1) a Medicare-certified HOSPICE that meets the Management and Pain Control conditions of participation for providing INPATIENT care directly as specified in ; or (2) a Medicare-certified hospital or a 42 418. 108(a) skilled nursing facility that also meets the standards specified in (b) and (e) regarding 24-hour nursing services and patient areas. [Note: Does not apply to respite services agreements.]. INPATIENT Care for Respite (1) INPATIENT care for respite purposes must be provided by one of the following: Purposes 42 418. 108(b) a provider [qualified to provide INPATIENT care for symptom management and pain control] specified in paragraph (a) of this section; or a Medicare or Medicaid-certified nursing facility that also meets the standards specified in (2) The facility providing respite care must provide 24-hour nursing services that meet the nursing needs of all patients and are furnished in accordance with each patient's plan of care.

10 Each patient must receive all nursing services as prescribed and must be kept comfortable, clean, well-groomed, and protected from accident, injury, and infection. * INPATIENT Care Under If a HOSPICE has an arrangement with a facility to provide for short-term INPATIENT care, the arrangement is described in a written Arrangement Written agreement, coordinated by the HOSPICE , and at a minimum specifies: Agreement 42 (c). * Policies and Procedures That the HOSPICE supplies the INPATIENT provider a copy of the patient's plan of care;. 42 (c)(2). *Specify INPATIENT Services The INPATIENT services to be furnished;. 42 (c)(1). *Copy of Plan of Care That the INPATIENT provider has established patient care policies consistent with those of the HOSPICE .