In the Hospice Final Rule last year, a change was made to the Conditions of Participation for hospices that states they could now have family therapists and mental health counselors as part of their Interdisciplinary Group (IDG). However, understand that it is not required for hospices to hire marriage and family therapists, or mental health counselors. This change was implemented because it has been acknowledged that these professionals can provide the necessary counseling services required by the Hospice Conditions of Participation.

It’s important to note that another aspect of the Condition of Participation includes providing access to social services for patients. Along with counseling, social services are a required component of the Condition of Participation. Marriage and family counselors, as well as mental health counselors, cannot fulfill the social work aspect of this requirement. Therefore, even if a hospice chooses to hire one of these professionals, they will still need to have a dedicated social worker on their team.

Additionally, it is important to remember that a longstanding part of the Conditions of Participation states that social worker services for hospice patients must be conducted by a social worker who holds a master’s degree in social work. While hospices can employ social workers with a bachelor’s degree, they must be supervised by a social worker with a master’s degree.

Marriage and family therapists, as well as mental health counselors, can be included as part of the IDG and play a role in developing the care plan for a patient. It’s important to note that if therapists or counselors are hired, they must be direct employees and cannot be contracted. They can be salaried, hourly, or per diem employees, but the key is that they must be considered direct employees. This also means that they can serve as volunteers, as volunteers are considered employees of the hospice.

During the Hospice Open Door Forum held on November 29, a question and answer session took place addressing various inquiries related to marriage and family therapists and mental health counselors. To read a transcript of the Q&A session, click here.

Should you have any questions regarding social work and counseling services for your hospice patients, please feel free to reach out to us.

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