Hospice Deficiency: Care Plans

The hospice plan of care is consistently flagged as a CMS top deficiency for hospice agencies.  According to CMS in 2019 nearly 60% of hospices got flagged for a deficiency relating to plan of care and hospice aide services

Click here for the full OIG 2019 report: https://www.hospicetools.com/wp-content/uploads/2020/09/Hospice-Deficiencies-Pose-Risks-to-Medicare-Beneficiaries-OIG-Report.pdf

1. What is a Hospice Plan of Care and Why is it Important?

The plan of care is the interactive road map for the patient, the patient’s family/caregivers, and hospice disciplines. The road map guides everyone involved in the patient’s care on the needed interventions to reach the care goals throughout the patients care lifecycle.

• The initial care plans are completed based off of the initial and comprehensive assessments.
• It is required to have care plans in place before services or care is provided for the patient.
• The plan of care should include an outline of the patient’s issues and what interventions or actions should be taken to achieve clear goals for each issue. The care plan will include medication or equipment orders for the patient.
•  It also must be updated by every IDG so at least within every 15-day frequency.
• Care plans are one of the most critical forms to complete, track, and manage the hospice lifecycle. A comprehensive and regularly updated care plan allows each discipline on any given day to know exactly what issues the patient and caregivers are dealing with and what is the game plan to help reach your goals.

Remember: because this is hospice care and not curative healthcare the care plan goals are not necessarily designed to cure the patient’s issue, rather the goal is often to alleviate symptoms; to make the issues manageable within the philosophy of comfort and quality of life for terminal patients.

2. Where Care Plans Go Wrong

 Hospice has many moving pieces with constant changes to the patient’s issues, medications, DME, care-giving, discipline changes, updates with regards to patient care and more.

Common issues that can come up with a care plan are:

A. Failure to follow the care plan.

Team members will often build familiarity with the patient and caregiver. While this familiarity is fantastic as it relates to interpersonal relationships, bedside manner, and wanting to deliver quality care, it often means that the care provider feels comfortable delivering care with the knowledge they have rather than checking, following, and updating the actual care plan.

Too often the care plan is thought of as just required paperwork that must be completed for regulatory reasons rather than as a functional guide to delivering care.

Not delivering care according to the plan can be a severe violation and can be a detriment to the patient’s care and the hospice agency.

B. Not updating the care plan:

The issue of not updating care plans on at least a bi-weekly basis is directly related to the point above: are care plans in your agency used to deliver care or are they thought of as post-facto paperwork to check the regulatory box?

If your care plans are not updated regularly it is a flashing red warning sign that your hospice team members are not using the care plans to guide their delivery of care.

Furthermore, simply updating at the 2-week mark in bulk will potentially be caught as deficiencies because as the care of plan changes, patients, family members, caregivers constantly be updated by all disciplines.

C. Personalized and individualized care plans

Each patient is a unique individual. However, many care plans are not. In large part, many care plans suffer from a lack of personalization because the underlying issues across patients may be similar.

For example, most hospice patients are prescribed opioids for pain management. How many ways can you personalize that you are providing meds for pain?

It is imperative that the hospice team members creating and updating care plans focus on the individual, not just the treatment.  While the same or similar problems and interventions crop up across patient profiles, the observations of the problem being addressed in a care plan that your team inputs allows a focus on the person and their particular set of circumstances.

Simply putting down the same problems and interventions across your patient profile without taking the time to personalize the observations and occurrences of the issue is a recipe for disaster.

if your team members are approaching their care holistically and not situationally, meaning treating the whole person rather than simply attempting to resolve a specific clinical issue, then personalizing a care plan should naturally flow from their patient interactions.

When your care plans all look the same it means your clinicians are looking at the pain and not seeing the person.

3. Ensure Care Plan Compliance

1. Communication is key to maintaining accurate and complete care plans. Team communication and accountability is a greater tool than all the automatic alerts your software could ever send. Find out why alerts and increasingly locked down systems won’t solve but will exacerbate your problems: https://www.hospicetools.com/hospice-emr-design-usability-is-your-greatest-audit-shield/
2. Every team member assigned to a patient must hold each other accountable to ensure care plan is constantly being updated.
3. Your IDG agenda sheet & dashboard should clearly display all open care plans and last date of update for each. When all the team members are gathered together, whether in-person or remotely, with the care plans listed intuitively listed and detailed as part of your IDG process, that workflow creates a seamless path to ensure care plans are reviewed, updated, and personalized.
4. Use a scheduling tool to set or review if care plans are being updated as part of the patient visits. Your EMR should also attach care plans to your patient visit note form putting the care plans in front of you right when your team needs them.
5. The care plan creator in your EMR should offer a full library of care plans broken down by discipline with editable prompts for goals and interventions. This allows your team members options for goals and interventions as well as a jumping off point for the standard base line issues so they can focus on personalizing and individualizing the plan.

Hospice Care Plans are consistently at the top of the CMS 10  Most Frequently Cited Survey Deficiencies. Find out how Hospice Tools delivers a better process.