Keys to Compliance With Hospice Volunteer Rules

Tracking compliance with volunteer requirements can be a challenging feat for hospices.

Medicare Conditions of Participation (CoPs) stipulate that volunteers must provide a minimum of 5% of hospice patient care hours through either daily administrative or direct patient care services. 

A main challenge is that various volunteer activities fall outside of this scope, according to Lori Asmus, manager of integrative services at Ohio-based Hospice of Cincinnati. Hospices must have mechanisms that monitor volunteer services and scope to help them remain compliant, she indicated.

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“We’re in a highly regulated environment and it can be pretty complex,” Asmus told Hospice News. “A big part of it is understanding that volunteerism falls into two broad categories of patient-facing and administrative support. You need to be careful that there isn’t an over-inflation of volunteer hours, which can get hospices in a lot of trouble. Having everything laid out specifically of how and what you count as volunteer service hours is really important, so that when an auditor or surveyor team comes you can explain the exact rules you follow to be compliant.”

Hospice of Cincinnati currently has an average rate of 9.7% patient-facing hours, according to Asmus. Direct patient care represents hospices’ most significant area of volunteer need, whereas administrative support has less opportunities, she stated. This trend means hospices have to be creative with the administrative roles that volunteers can provide assistance in, Asmus stated.

An imbalance of volunteer needs can complicate a hospice’s journey toward compliance, she said. Tracking volunteer hours successfully can involve coordination across an organization, including technical and interdisciplinary teams that help oversee these activities.

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“There’s a lot of technical barriers,” Asmus said. “So we utilize digital forms specifically built for our volunteers to accurately capture their time and activity and help identify whether it was a patient experience or administrative task. It also provides coordination with the interdisciplinary team if immediate communication with a patient is needed after a volunteer visit. It saves us a lot of time and is a high satisfier.”

Certain volunteer activities may enhance a patient or their family’s experience, but not qualify as part of the CoPs. It’s important for hospices to understand the definitive lines in volunteer regulations, said Greg Schneider, president and founder of the Hospice Volunteer Association (HVA) and founding director of the nonprofit Hospice Educators Affirming Life (HEAL) Project.

Among the resources that HVA offers hospices are a system of volunteer tracking forms that help discern the types of activities performed and the amount of hours they contributed that were patient-centered or administrative in nature. For instance, knitting blankets for patients is not an activity that falls into the scope of the 5% volunteer requirement,

“Hospice volunteerism continues to evolve as part of the changing business climate, and that can make things foggier as far as the methods available to track it,” Schneider told Hospice News. “The biggest thing that affects continuity of hospice volunteer programs is the ability to meet the 5% requirement. There are a large variety of different kinds of roles that volunteers can play … and the hours can be tracked in a simplified way so that you can see which activities are in that 5% concentration.”

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