CMS 1754-F Hospice Conditions of Participation Changes Finalized- Competency Changes

On July 29, 2021, CMS rule 1754-F was finalized and while it is entitled the 2022 Hospice Payment Rate Update, the rule makes final the proposed changes to the Hospice Conditions of Participation.  This month, our focus is on the adopted changes to the hospice aid competency evaluation changes that are contained within rule 1754-F.

While many of you will be focused on the changes in the reimbursement rates and the quality measure changes, there is a small section that will require each organization to evaluate their current competency assessment process to ensure alignment with these new requirements.

During the Covid-19 Public Health Emergency, there were numerous waivers granted by CMS that were designed to support the ongoing delivery of care to hospice clients.  These waivers were deigned to permit more flexibility and reduce unnecessary burden in the delivery of care.  One such waiver permitted the use of “pseudo-patients” for use during hospice aide training-competency assessments.

CMS Condition of Participation § 418.76 which addresses hospice aide and homemaker services, now permanently permits the use of either real patients or pseudo-patients as an option when observing the hospice aide or homemakers’ delivery of specific skills in delivering care.  Note that the following definition of pseudo-patient and simulation are now embedded within the Conditions of Participation:

  • Pseudo-patient means a person trained to participate in a role-play situation, or a computer-based mannequin device. A pseudo-patient must be capable of responding to and interacting with the hospice aide trainee and must demonstrate the general characteristics of the primary patient population served by the hospice in key areas such as age, frailty, functional status, cognitive status, and care goals.
  • Simulation means a training and assessment technique that mimics the reality of the homecare environment, including environmental distractions and constraints that evoke or replicate substantial aspects of the real world in a fully interactive fashion, to teach and assess proficiency in performing skills, and to promote decision making and critical thinking.

Additionally, the requirements now necessitate for hospice organizations to conduct a competency evaluation related to any deficiency of related skill(s) noted during a hospice aide supervisory visit. This change permits the organization to focus on the specific areas identified as needing improvement in the hospice aides’ skills instead of requiring a full competency assessment, inclusive of areas where documentation already exists of the staff’s acceptable skill level, within the competency evaluation. This will allow a more efficient means of re-training existing aides more quickly to return to the workforce to provide high quality patient care.

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