The top ten hospice Medicare certification/recertification survey deficiencies have remained fairly consistent for the past several years. Below is the top ten list for 2017.

For calendar year 2017, nine of the top ten deficiencies were the same as in calendar year 2016 – with L531 coming on the list at number ten and L591 – Nursing Services dropping out of the top ten but not far. It is the twelfth most frequently cited deficiency. The plan of care, L543, remains at number one and for many years, if not at number one, has been in the top three. Nearly 10% of hospices surveyed in 2017 were cited for not complying with this plan of care standard. And, half of the top ten deficiencies are related to the plan of care. The types of issues leading to a deficiency under L543 – Plan of Care include:

  • Not delivering care according to the plan of care
  • Not having orders for items on the plan of care
  • Not including the required individuals in development of the plan of care
  • Not incorporating updated comprehensive assessment information into the plan of care/not individualizing this information

Surveyors found that hospices did not observe visit frequencies on the plan of care or deliver the interventions listed on the plan of care. Hospices should refer to the plan of care before each visit to ensure delivery of the interventions listed/modify the interventions so the plan reflects what is truly necessary. Hospices should also remember that the attending physician (if any) is part of the interdisciplinary group (IDG) responsible for establishment of the plan of care as is the social worker and chaplain, even if these individuals are not actively visiting the patient. These disciplines were made part of the IDG because of the value they bring to hospice care and should be consulted as part of the team in the development of the plan of care. If the patient refuses the social worker/chaplain, the RN should consult with the social worker/chaplain on the psychosocial/spiritual assessment results in order to establish the plan of care. Healthcare Provider Solutions, Inc. is available to assist hospices in practices that promote compliance with the top ten deficiencies.