A proposed House bill, Helping Our Senior Population in Comfort Environments (HOSPICE) Act, could increase accreditors and U.S. Centers for Medicare & Medicaid (CMS) survey frequency from every three years to every other year for hospices. These provisions — and the public reporting of accreditation survey results — could weigh heavily on both accrediting organizations and hospice providers, who are already stretched thin under pressures brought on by the novel coronavirus pandemic.
In response to July 2019 reports on hospice quality from the Office of the Inspector General (OIG) at the Department of Health and Human Services (HHS), both the HOSPICE Act and corresponding Hospice Care Improvement Act introduced in the Senate are intended to improve quality of care for patients and families. If enacted, the legislation would implement new rules for oversight and transparency.
“Increasing the survey frequency would require that hospices seeking accreditation pay more frequently to have a survey done for their organization,” according to a statement emailed to Hospice News from The Joint Commission. “It would also mean that staff time (and associated costs) devoted to the onsite survey and follow-up would increase. The current bills being considered by Congress would also increase training requirements for surveyors, which would need to be incorporated into our operations.”
If the bill is enacted, these drawbacks could come during a continued state of national emergency. Weathering the financial strains of responding to the COVID-19 pandemic has been an ongoing struggle for many hospice providers. As states reopen and hospices look ahead to recovery after the outbreak, providers may be faced with additional headwinds resulting from increased accreditation survey frequency.
“The suggested increase in survey frequency would undoubtedly raise accreditation costs for hospices,” said Susan Mills, associate clinical director, Accreditation Commission for Health Care (ACHC). “If hospices decide not to pursue accreditation and rely on the authority of the State, they would be susceptible to monetary sanctions for deficiencies.”
Despite the potential increased costs resulting from increased survey frequency and potential deficiency penalties, hospices could stand to benefit from the proposed legislation’s new rules.
“While we would try to minimize the impact to hospices, overall the higher costs could be seen as an investment,” said Mills. “If the increased survey frequency results in improved safety and quality of care, it would shelter the organization from potential sanctions, which could be severe.”
Among other provisions, the HOSPICE Act would give authority to CMS to post independent accreditation survey reports on the agency’s Hospice Compare website. Historically, these reports have been kept confidential and not available for public viewing. Openly reporting accreditation survey results could benefit hospices hoping to stand out in a crowded market.
“This [legislative] effort can allow hospices that deliver quality care to shine and raise the bar in the industry,” said Barbara McCann, chief quality officer at Community Health Accreditation Partner (CHAP). “Public reporting could at the least make elements of quality care more evident and clear to the consumer, as well as to medical providers who are critical in making a referral to hospice.”
While increased information could potentially benefit patients and families comparing options for quality end-of-life care, accreditation survey results can be difficult to interpret and possibly lead to more public confusion and misperceptions of hospice care.
Some stakeholders believe that the general public would not be able to understand reports on accreditation survey results or that the move could have a chilling effect on communication between accreditors and providers, according to The Joint Commission.
“Making current accreditation survey reports public would cause several unintended and adverse consequences,” stated The Joint Commission. “All of these adverse consequences can be eliminated if there is a standardized report that focuses on compliance with the CMS Conditions of Participation. The Joint Commission strongly supports engaging with CMS and other stakeholders to produce a publicly available, standardized format that includes survey information that is easily understandable by patients and their families and focuses on the government’s health and safety requirements. This will enable the public to compare all hospice providers and their associated deficiencies regardless of whether the hospice provider is surveyed by the state survey agency on behalf of CMS or by an accrediting organization.”
One potential long-term outcome could be closer ties among hospice care providers and federal and accrediting agencies. Increased communication involved with the accreditation survey process could improve a greater understanding not only for providers in how to utilize survey results, but also the patients and families they serve in their final life stages.
“This is a great, unique opportunity for CMS and the accrediting organizations to work together and translate the regulations into the essence of what is being measured for patients and families,” McCann told Hospice News. “A key concern is that pain will be effectively responded to, or supporting the caregiver in the patient’s wish to remain at home. Ultimately, the suggested increase in survey frequency is to ensure continuous compliance and improved quality of care.”