Grief During the Holidays

For those mourning a loved one – whether a recent death or one long ago – the holiday season which is customarily marked by celebrations and family gatherings can be full of painful reminders that heighten  the sense of loss. Often, friends and family members of those affected by a loss are unsure how to act or what to say to support someone struggling during the holidays.

Here are some tips: 

1.  Be understanding and supportive if someone wants to do things differently this holiday season.  Some people find strength in long established traditions while others may choose to avoid customs of the past and do something new. It’s okay to do things differently.

2.  Offer to help with decorating or holiday cooking. Both tasks can be overwhelming for someone who is grieving or overwhelmed by events going on in the world around us. Lending a hand can be a great way to let someone know you’re thinking about them and their wellbeing. 

3.  Invite someone to join you or your family during the holidays.  If someone you know seems down or depressed, consider inviting them to join you for a holiday concert, religious service or a holiday meal where they are a guest. You might even offer to accompany them on a holiday shopping trip where a friend and extra set of hands can be helpful.

4.  Ask the person if he or she is interested in volunteering with you during the holidays. Doing something for someone else, such as helping at a soup kitchen, staffing a coat drive, or working with children, may lift your spirits and help everyone feel better about the holidays. 

5.  Never tell someone that he or she should get ‘over it.’  It can be important to acknowledge that a friend or loved one is struggling. Don’t discount their emotions, but give the person hope that, eventually, he or she will enjoy the holidays again.

6.  Be willing to listen.  Don’t avoid someone because you don’t know what to say. Active listening from friends and family is an important step to helping someone coping with grief or overwhelming feelings of loss. Letting them share their feelings can help healing.

7.  Don’t be afraid to remember someone who has died.  When someone is grieving, it is okay to let them know that you are thinking of the loved one who died. Cards, phone calls and visits are great ways to stay in touch.

8.  Follow up after the holidays to check in.  Given the activity of the season, some people may make it through the holidays without any issues but they might find the post-holiday period to be more difficult. So circling back after the holidays to see how he or she is doing can help.

Hospice and palliative care professionals have always recognized the need to provide emotional and spiritual support to those who are dealing with loss. Hospices often offer support to community members struggling with grief or loss so those struggling should check with a community hospice to see if support is available.

To learn more about grief or coping with loss, or to find a hospice and palliative care provider in your area, visit NHPCO’s CaringInfo website at www.caringinfo.org.   

Veterans Bond Over Coffee and Conversation

December 7, 2016 marked the 75th anniversary of the attack on Pearl Harbor. As a day to honor and remember, many organizations and We Honor Veterans partners held events to pay tribute to all Veterans, particularly those who served in WWII. I was lucky enough to attend a special event held in Welcome, North Carolina by We Honor Veterans Level 3 partner Hospice & Palliative CareCenter.

Many partners hold coffee events in their community as a way to bring Veterans together to share stories, giving them an extremely rare outlet. As a special commemoration event, Hospice and Palliative CareCenter organized an event of epic proportions. It was held at the Richard Childress Racing Museum and over 700 people were in attendance, including about 500 Veterans. What made the biggest impression was not the turnout, community collaboration or volunteers running around ensuring everyone had a seat and was taken care of – it was the comradery and the friendships that have come out of something as simple as getting together for a cup of coffee. 

I met a gentleman who was held as a POW for over a year during WWII. It came as no surprise that he became humbled when I thanked him for his service, saying he was surprised that so many people were interested in his story while adjusting the Purple Heart hanging around his neck. He shared that while he still has flashbacks and may never be able to find forgiveness, this past year has been his hardest by far. He lost his wife of 74 years and said that living without her is the toughest thing he’s ever had to endure, adding that he didn’t know if he would make it past Christmas. As tears started falling a few of his buddies within earshot immediately joined our conversation, offering support that could only come from a fellow Veteran. They insisted that the “lonely boys” be with each other at Christmas, one (half-jokingly) adding that he had to be alive for the next Veterans Coffee in January as they would be riding together.

These community events and activities only happen because of the loving service and dedication of our We Honor Veterans partners. Ann Gauthreaux of Hospice & Palliative CareCenter and Rowan Hospice & Palliative Care is one of the forces behind this partner program and nicely summed up the importance of their program activities:

“To say our Veteran Coffees are well attended and heartwarming would be an understatement. They have become a part of life for our region’s veterans. A place to share stories, find common ground, and enjoy comradery. The expression; ‘If you build it – they will come’ has never seemed more appropriate. We make sure they know about our programs and services, yet it’s so much more. The coffees are a melting pot for all veterans and things related to veterans!”

To learn more about the We Honor Veterans program, visit www.wehonorveterans.org  or contact us at veterans@nhpco.org.

By Katherine Kemp
Access Manager, NHPCO

Palliative Care and Changing Policy Landscape

NHPCO was invited to submit an article to the American Journal of Managed Care about policy issues related to palliative care. The article is available online. "With the incoming Trump Administration and a new Congress about to begin, the future of palliative care policy is very uncertain," reports Sharon Pearce, NHPCO vice president for public policy.

In the article, “Palliative Care for Patients With Advanced Illness: A Changing Policy Landscape,” published this week by the American Journal of Managed Care, Pearce shares insight into possible policy implications for palliative care in the year ahead.

The article begins:  “Every day, 10,000 Americans join the Social Security and Medicare rolls. Moreover, individuals 80 and older are the fastest growing demographic among older adults, with their ranks forecast to grow from 5.6 million in 2010 to more than 19 million by 2050. The rising number of aging Americans creates a commensurate increase in the costs for healthcare.”

Pearce goes on to explain the value of the interdisciplinary team model of care provision and the importance of providing palliative care services to the seriously ill. Many barriers are challenging access to these services, however, progress is being made.

“In lieu of sweeping policy changes, palliative care advocates have adopted a more incremental approach. Recent policy changes, primarily in the ACA, are allowing small-scale testing of community-based palliative care delivery, and for some innovations in other delivery systems. Other administrative changes are slowly increasing access to Advance Care Planning. While many of these demonstrations are still playing out, some models, including the Medicare Care Choices Model (MCCM), accountable care organizations (ACOs), and the Independence at Home Demonstration, are showing early promise.”

Read the complete article on the AJMC website.

 

Thank You from Don Schumacher

When I began my professional career, 44 years ago, I never would have guessed the unique, surprising, fulfilling and meaningful career that would unfold before me. I was going to be an English professor, but my contact with Elizabeth Kubler Ross in 1975 put my feet on an entirely different path. I have been able to work with the most extraordinary people to create a model of caregiving that had been missing in our healthcare system for a very long time. These people, of which you are one, have been my teachers, critics, friends, conspirators, pranksters, dining and drinking friends and most importantly, fellow advocates ensuring the permanence of hospice and palliative care in America.

As I prepare to retire from NHPCO, I want to thank you for all you have done for the millions of Americans who have received your loving care. There is no one who stands at the bedside of a dying patient and remains untouched. I remember the first patients I cared for and the hospice team members with whom I shared my fears, energy and skill at helping that patient move on. I thank them and their descendants, you, for all you have done and continue to do for the millions who benefit from our care.

I want to thank the many of you who I have been lucky to call friends. The path has not always been smooth, and all of us have tried to be as supportive of each other as we can. However, when you are creating a movement, a new care giving model and a team based model of care, things are bound to go wrong. Pay no mind, I ask you. For what we have created went more right.

I will continue to consult with programs and people in the field so I hope to continue to see you occasionally. But…… remember every day you work in hospice and palliative care, you are building the bed you will die in. Make sure it is the one you want. From the bottom of my heart, I honor you for what you do every day. Love---

Don

J. Donald Schumacher, PsyD
President and CEO
National Hospice & Palliative Care Organization

P.S.  I have a link I would like to share with you, Judy Collins singing "In My Life," a song that has always held special meaning for me, particularly in recent weeks. Additionally, a special NHPCO Podcast has been posted where I share reflections from my career.  I invite you to listen to both of these.

MedPAC – December 2016

It’s that time of year again, everyone! The Medicare Payment Advisory Commission, or MedPAC, held its December meeting last week, and started hearing a series of reports that will ultimately inform the annual March Report to Congress. Among the reports the Commission heard was “Assessing payment adequacy and updating payments: hospice services.” In this report, MedPAC staff provided an overview of the Medicare Hospice Benefit and recent changes to end-of-life care (like the Medicare Care Choice Model demonstration). The staff also presented data on the average length of stay  and live discharge rates by different beneficiary characteristics and provider types. You can view the slides and transcript from the hospice session on the MedPAC website.

Each report ends with a Chairman’s recommendation. For hospice, the recommendation is:

“The Congress should eliminate the update to the hospice payment rates for fiscal year 2018.”

MedPAC has made this same payment update recommendation to Congress for the past 4 years, at minimum. There is one important thing to remember about MedPAC, however. As its name indicates, MedPAC is an advisory commission to Congress. Congress must take proactive steps to implement MedPAC recommendations, and it has not done so with regard to the payment update recommendation in recent years.
However, Congress does read the reports and once policy proposals are made, they live forever. You can never rule out Congress acting on recommendations now or in the future. Keep an eye out for more updates from MedPAC as the release of their annual report approaches.

By Karen Davis, MA
Manager, Health Policy Analysis

Follow the Hospice Action Network blog for additional articles of interest. 

December 1 is World AIDS Day

World AIDS Day is a global initiative to raise awareness, fight prejudice, and improve education about HIV, the virus that causes AIDS. World AIDS Day is December 1. Around the world, about 37 million people are living with HIV. In the United States, about 44,000 people get infected with HIV every year.

In recognition of World AIDS Day on December 1, the U.S. Office of Disease Prevention and Health Promotion encourages everyone to get tested for HIV, the virus that causes AIDS. In the United States, about 1 in 8 people who has HIV doesn’t know it. The only way to know for sure whether or not you have HIV is to get tested. You could have HIV and still feel healthy. 

Everyone ages 15 to 65 needs to get tested at least once. Some people may need to get tested more often. To find an HIV testing location near you, text your ZIP code to KNOWIT (566948) or use this online locator (http://locator.aids.gov).

HIV is passed from one person to another by:

• Having unprotected sex with a person who has HIV
• Sharing needles with someone who has HIV
• Breastfeeding, pregnancy, or childbirth if the mother has HIV
• Getting a transfusion of blood that’s infected with HIV (very rare in the United States)

Learn more about HIV/AIDS and how to prevent this disease from the following websites:

• AIDS.gov
• UNAIDS
• National Institute of Health
• CDC

Save on 2017 Webinar Packages

NHPCO Webinars bring you and your staff expert guidance from nationally recognized authorities on important topics of the day — at rates as low as $67 per Webinar. Order your 2017 webinar package by 12/31/2016 in order to take advantage of the early-bird package pricing. 

Two Webinars are offered each month — with one focusing on an interdisciplinary topic and the other on a quality or regulatory topic. The topics are generated and vetted by your peers so you can be assured that the content is relevant to the field. The annual calendar is developed with input from several NHPCO Committees as well as from the Educational Needs Assessment Survey. The calendar of 2017 Webinars is available online.

New this year, a MP4 recording will be included with your Webinar purchase giving you the opportunity for staff to listen to the valuable discussions after the original presentation (CE/CME is only available for participation in the live Webinar broadcast and not for those who listen to the MP4).

Member Rates for Webinars that include MP4s

• 24-Webinar Package:  $1,625 if you order by 12/31/16; $1,829 afterwards.
• 12-Webinar Package:  $865 if you order by 12/31/16; $975 afterwards.
• 6-Webinar Package:  $460 if you order by 12/31/16; $515 afterwards.
• Single Webinars:  $85 if you order by 12/31/16; $95 afterwards.

For Webinar details or to register, visit nhpco.org/webinar. Or download our 2017 Webinar Early Bird Order Form – but you must get it in by December 31, 2016 to get the early bird savings.

 

This Thanksgiving Talk about the Care You Would Want

A family is gathered by the bedside of a loved one who has been seriously ill, and now is likely near the end of life. Each member of the family has a different idea of what should be done and what their loved one would have wanted. That’s the point when they realize they should have planned ahead and talked about what they each would want in a medical crisis.

Heartbreaking scenes like this happen far too often.

The National Hospice and Palliative Care Organization is encouraging families to spend time when they may be gathered for the holidays, to talk about the care they would or would not want. This is particularly important if a family is coping with a serious or life-limiting illness of a loved one.

Having discussions about one’s health care wishes is part of advance care planning.

Advance care planning involves making decisions about the care you would want to receive in a medical crisis that might be the result of a serious illness or an unexpected accident.  Advance care planning also involves deciding who will speak for you if you are not able to speak for yourself. An essential part of advance care planning involves having these important conversations with your loved ones.

Advance care planning also includes:
•    Deciding what types of treatment you would or would not want should you be diagnosed with a life-limiting illness or faced with a serious medical crisis.
•    Sharing your personal values and beliefs with your loved ones.
•     Completing an advance directive to put into writing what types of treatment you would or would not want.
•     Designating a person as your health care power of attorney (sometimes called a health care proxy) to speak for you if you cannot speak for yourself.

NHPCO’s CaringInfo.org offers free state-specific advance directive forms and free information to help families talk about the care they would want. Visit caringinfo.org/planningahead.

Watch NHPCO's video on advance care planning.

Post-Election Recap from NHPCO

Hear from the leaders of the National Hospice and Palliative Care Organization's Health Policy Team, Jon Keyserling and Sharon Scribner Pearce, on their takeaways from this election.  They discuss some of the outcomes of the election, what we might expect in the first 100 days and offer insight and advice for the hospice and palliative care community.

A major point to emphasize is that hospice and palliative care benefit from support on both sides of the aisle on Capitol Hill and end-of-life care had not been an issue of debate during the election campaign season.

Listen to the Special Election Podcast.

Other NHPCO Podcasts look at a number of relevant regulatory and compliance issues that are important for hospice providers. Listen to these podcasts via itunes, GooglePlay and Stitcher. Or find them on the NHPCO website at www.nhpco.org/podcast.

Hospice Volunteers Honored for Outstanding Service

NHPCO recognized five outstanding volunteers at the organization’s event, The Intensives, hosted in Hollywood, Florida, October 31 through November 2. The Volunteers are the Foundation of Hospice Awards were created by NHPCO’s National Council of Hospice and Palliative Professionals to recognize hospice volunteers who best reflect the universal concept of volunteerism in its truest sense—serving as an inspiration to others.

Chosen from more than 200 nominations, this year’s dedicated honorees were:

Clyde Day, a volunteer with Peterson Hospice in Kerrville, Texas, honored for organization support. In 1984, Clyde worked with other community members to donate their time and raise money to start Heart of the Hills Hospice in Kerrville. He helped negotiated the agreement between Peterson Memorial Hospital and the Hills Hospice which was the beginning of Peterson Hospice where he currently volunteers. Day’s service has included visiting patients, delivering flowers, sweeping floors, building shelves in the Thrift Store, as well as serving on the Board.

Karen Jackson, a volunteer with Suncoast Hospice / Empath Health in Clearwater, Florida, was honored for Specialized Volunteer Service primarily for her work with the hospice’s perinatal loss doula program for which she has served since it began in 2004. With more than 1,600 hours of service, she has often served as the “voice” of the program, playing an instrumental role in public speaking events, attending advisory board meetings, and presenting the program at local and national events and conferences.

Ryan Regan, a young volunteer with Suncoast Hospice / Empath Health in Clearwater, Florida, was recognized for his contributions to the hospice’s Teen Volunteer Program. Since January 2014 he has contributed more than 1,000 volunteer service hours in support of more than 240 families. Regan was selected to serve as one of six members of the Suncoast Hospice Teen Volunteer Regional Leadership Board/North County. He is active in the recruitment of teen volunteers and serves as a mentor to young people coming into the volunteer program.

Colonel Patsy Thompson, a volunteer with Sutter Care at Home Hospice in Roseville, California, was honored for Specialized Volunteer Service. In her twentieth year of volunteering for the hospice, she began by visiting patients with her spouse and their dog Pretzel. Now, Thompson has taken the lead of the “We Honor Our Veterans” ceremony program where she has been honored by the community and continues to serve with gusto.

Ingrid Watt, another volunteer with Suncoast Hospice / Empath Health in Clearwater, was recognized in the Patient and Family Support category.  She began her volunteer journey with Suncoast Hospice in 1993 and has provided over 2,900 hours of service in caregiver relief, transportation, Transitions Companion visits, and bereavement support for patients and their families. Through her volunteer work, she has become a Reiki Master and uses this therapeutic technique in her work with patients.

“Volunteers play an integral role in hospice care and each and every one deserves recognition and the highest accolades.  From direct patient support and caregiver relief to board service and community outreach and education,  hospice volunteers selflessly give of their time to serve patients and families who are facing end-of-life challenges and are integral to the hospice programs for which they serve,” said J. Donald Schumacher, NHPCO president and CEO.

The awards were presented by NCHPP Chair Rex Allen and NCHPP Vice-Chair Sandi Huster who also serves as the section leader for the Volunteer/Volunteer Management Section.

L to R: Rex Allen, award recipient Ingrid Watt with Kathy Robel of Suncoast Hospice/Empath Health, and Sandi Huster.

Lyle's Hawaiian Dream

Dream Foundation Provides Trip of a Lifetime to Young Man with Advanced Illness

Te National Hospice and Palliative Care Organization released a new video today as part of the “Moments of Life: Made Possible by Hospice” public awareness campaign.  The video features Lyle Romans, a 21 year-old with terminal lung disease and dermatomyositis.  “Lyle’s Hawaiian Dream” shows Lyle and his foster family on a journey from his home in Oregon to the beautiful beaches of Waikiki, Hawaii.  His trip was made possible by Dream Foundation, the only national dream-granting organization for terminally-ill adults. 

Lyle, who has lived with the Dobbs family since he was 18 years-old, was an active teenager.  In his senior year, he was diagnosed with lung disease and since then his health has continued to decline.  He has lost 80% of his lungs due to scarring and cysts. He no longer has the ability to walk or move his neck and he is losing his sight.  Lyle’s dream was to go to Hawaii to see and experience the natural beauty of the islands before his sight was completely gone. Dream Foundation stepped in to make Lyle’s Dream of a Hawaiian vacation a reality.   Lyle and his family visited the island of Oahu in June.  

In the video, Lyle can be seen enjoying the sights of Oahu including the famous Halona Blowhole and Sea Life Park Hawaii.  Palliative care helped stabilize Lyle enough to be at home with his family and strong enough to enjoy this trip.  

Lyle’s video is part of the “Moments of Life” public awareness campaign launched by the National Hospice and Palliative Care Organization in 2014.  The campaign features stories from hospices and palliative care programs across the United States of patients and families experiencing hospice and palliative care first hand.   The “Moments of Life” website has information available on palliative care.

 

“Hospice Helps Everyone” Message Reaching Latino Communities

The National Hospice and Palliative Care Organization’s “Moments of Life: Made Possible by Hospice” campaign has released a new video translated in Spanish and showcases the benefits of hospice care. “Un Baile Para Gloria” features Gloria, an 85 year-old Latina and former schoolteacher from Pueblo, Colorado, who suffers from COPD, a condition that confines her to her home. The video which was first produced in English, was translated to Spanish to use for outreach in the Latino community where hospice utilization is disproportionately low.

Gloria is cared for by Sangre de Cristo Hospice. The video features a special event her care team organized to honor her love of culture, music, dance, and prayer. Gloria’s care team honors her Latino heritage as well. One of Gloria’s caregivers, Carolina, is bilingual and speaks Spanish with Gloria during her visits. Carolina helps Gloria with her baths and showers. Having a caregiver who can speak to the patient in their native tongue can add ease to a situation that can be very stressful and uncomfortable.

“We are thrilled to release this video that highlights the benefits hospice can provide to all communities including the Latino population,” says NHPCO President and CEO, J. Donald Schumacher. “Many hospice providers serve diverse populations and it’s essential to understand each community’s end-of-life cultural beliefs and attitudes."

 According to Tarrah Schreiner, chief executive officer at Sangre de Cristo Hospice, many people on the team can speak Spanish.  Southern Colorado has a large Latino population and the organization services several Latino families like Gloria’s.

To support the work of hospice providers that service Latino communities, NHPCO’s Latino Outreach Guide is available online, free of charge. The guide outlines key principles and insights to help hospices better serve this diverse community.  

Gloria’s video is part of the “Moments of Life” public awareness campaign launched by NHPCO in 2014. The campaign features stories from hospices and palliative care programs across the United States of patients and families experiencing hospice and palliative care first hand. The “Moments of Life” website includes information in Spanish that helps explain hospice care and advance care planning. 

Gloria pictured with the Grupo Xochitl dance troop.

NHPCO Welcomes New Volunteer Section Leader to its National Council

NHPCO's National Council of Hospice and Palliative Professionals is pleased to introduce Stacy Groff, MNM, as the incoming Volunteer/Volunteer Management Section Leader.

Ms. Groff has served on the section’s steering committee since 2012 and has been a regular presenter at NHPCO conferences. Her presentations include Volunteer Mentors: A Key to Retention; Medicare Regulations for Hospice Volunteer Programs: Creating a Survey-Ready Program that Demonstrates Excellence; and Hospice Volunteer Leadership Development 101. Members of the section will recognize her voice from the many section chat’s she has hosted. In addition, Stacy contributed her expertise to the recently revised Hospice Volunteer Program Resource Manual.

Groff currently leads one of the largest volunteer programs in the country as the Director of Volunteer Services for Tidewell Hospice, which serves Manatee, Sarasota, Charlotte, and Desoto counties in Florida.

Outgoing Section Leader Sandi Huster says “I am very pleased that Stacy will be serving as our section leader and know that she and our outstanding steering committee members will continue to provide excellent service to the members of our profession.” Earlier this year Huster was chosen to be the next Chair of NHPCO’s National Council of Hospice and Palliative Professionals.  In that role, she will be on the board of NHPCO.

Ms. Groff and Ms. Huster will begin their three-year terms on January 1, 2017.

Stacy Groff, MNM

 

Birth of a New CoP for Medicare Hospice, Part 3

This is part three of a three part series focusing on the final rule for Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers (CMS-3178-F) for hospice providers.  This article will discuss the last two standards of this new Condition of participation (CoP) for hospice providers. 

The Communication Plan

The third standard in this new hospice CoP at §418.113 (c) requires a hospice to develop and maintain an emergency preparedness communication plan that that complies with Federal, State, and local laws and is reviewed and updated at least annually.  The communication plan outlines the names and contact information for hospice staff, contracted partners, and patient physicians as well as Federal, State, tribal, regional, and local emergency preparedness staff.  The plan must outline primary and secondary means for communication with hospice staff and Federal, State, tribal, regional, and local emergency management agencies to ensure optimal coordination of care and services during a disaster[i].

The communication plan must also delineate the process of how a hospice will share information and clinical documentation for patients under their care with other health care providers and Federal, State, tribal, regional, and local emergency management agencies to preserve continuity of care.  The release of patient information is critical in the event of patient evacuation and is permitted under 45 CFR 164.510(b)(1)(ii) which discusses when a covered entity may use or disclose protected health information without the written consent or authorization of an individual.  For hospices with an inpatient facility, this process would also include how information about a hospice's inpatient occupancy, needs, and its ability to provide assistance would be communicated to Federal, State, tribal, regional, and local emergency management agencies.  The process of patient information exchange during a disaster response serves as a means to discern the general condition and location of patients under a hospice facility's care[ii].

Training and Testing
The final standard in the CoP at §418.113(d) requires a hospice provider to develop and maintain an emergency preparedness training and testing program that is based on the emergency plan, policies and procedures, and the communication plan and is reviewed and updated at least annually.  Depending on the size of the hospice and their geographic location, elements in this part of the requirement may be the most difficult to implement. 

The training program:   The emergency preparedness training program must educate new staff, existing staff, and contracted partners about the emergency plan, policies and procedures, and communication plan consistent with their expected roles at least annually. As with all training, staff competency needs to be assessed and documentation of training needs to be maintained[iii].

Testing the program: A hospice must conduct two exercises to test their emergency plan at least annually.  One of the exercises requires ‘boots on the ground’ participation in a full-scale exercise that is community-based or individually facility-based.  The second exercise may include, but is not limited to a second full-scale exercise that is community-based or individually facility-based or a tabletop exercise that includes a group discussion led by a facilitator who utilizes a narrated, clinically-relevant emergency scenario, and a set of problem statements, designed to test an emergency plan.  The hospice must analyze their response to the exercise and maintain documentation of all drills, tabletop exercises, and emergency events, and revise the hospice's emergency plan, as needed based on the outcomes of the exercises.  If the hospice activates their emergency plan related to an actual natural or man-made emergency, they are exempt from engaging in a community-based or individually facility-based full-scale exercise for 1 year following the actual event[iv].

A hospice may be part of a healthcare system which includes multiple separately certified healthcare facilities.  If this is the case, that system may opt to have a combined and integrated emergency preparedness program and the hospice may choose to participate in the healthcare system's coordinated emergency preparedness program. In this scenario, the integrated emergency preparedness program must demonstrate that each provider within the system actively participated in the development of the unified emergency preparedness program and that it was developed and maintained related to the unique conditions, patient populations, and services offered by each provider.  This approach to compliance would need to include all of the required elements outlined in the CoP (emergency plan, policies and procedures, communication plan, and training and testing)[v].

(Read part one and part two.)

Jennifer Kennedy, MA, BSN, RN, CHC
NHPCO Senior Director, Regulatory & Quality 

---

[i] Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers; Final Rule. (2016, Sep16). Retrieved from https://www.gpo.gov/fdsys/pkg/FR-2016-09-16/pdf/2016-21404.pdf

[ii] Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers; Final Rule. (2016, Sep16). Retrieved from https://www.gpo.gov/fdsys/pkg/FR-2016-09-16/pdf/2016-21404.pdf

[iii] Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers; Final Rule. (2016, Sep16). Retrieved from https://www.gpo.gov/fdsys/pkg/FR-2016-09-16/pdf/2016-21404.pdf

[iv] Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers; Final Rule. (2016, Sep16). Retrieved from https://www.gpo.gov/fdsys/pkg/FR-2016-09-16/pdf/2016-21404.pdf

[v] Medicare and Medicaid Programs; Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers; Final Rule. (2016, Sep16). Retrieved from https://www.gpo.gov/fdsys/pkg/FR-2016-09-16/pdf/2016-21404.pdf