Define Direct Patient Care Hours

This discussion originated by Donna Balko on July 13, 2010 at 11:43am and was transferred by Greg Schneider to the Volunteer Management Group, as this is a topic of discussion appropriate to that group. 

 

PLEASE NOTE: Volunteer coordinators and managers please start your discussions in the group that best matches the topic of your discussion.  Thanks.

 

Donna asked the following question:

 

Define Direct Patient Care Hours

I have been a volunteer coordinator for 6 months now, but I am still not clear on what the regs are for "direct patient care hours".   I have been told the 5% required by Medicare is calculated from the total patient care hours provided by all paid hospice employees.  I guess my biggest question is - are team meetings, staff meetings, and staff trainings included in these hours.  If so, why are we not allowed to use volunteer training hours and volunteer meetings in calculating the 5%.  I would appreciate any help and/or if you could tell me where to go to get the information.  Thanks so much.

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Replies

  • The CMS Conditions for Participation (CoP) §418.70(b) Standard: Role, states:

    Volunteers must be used in administrative or direct patient care roles.

    HHS Guidelines state:
    Volunteers who are qualified to provide professional services should meet all standards associated with their specialty area. If licensure or registration is required by the State, the volunteer must be licensed or registered.

    The hospice may use volunteers to provide assistance in the hospice’s ancillary and office activities as well as in direct patient care services, and/or help patients and families with household chores, shopping, transportation, and companionship.

    The CMS Conditions for Participation (CoP) §418.78(e) Standard: Level of activity, states:

    "A hospice must document and maintain a volunteer staff sufficient to provide administrative or direct patient care in an amount that, at a minimum, equals 5 percent of the total patient care hours of all paid hospice employees and contract staff. The hospice must document a continuing level of volunteer activity. Expansion of care and services achieved through the use of volunteers, including the type of services and the time worked, must be recorded."

    HHS Guidelines state:
    In computing the level of activity that the hospice spends in administrative or direct patient care, the hospice may include the time spent orienting volunteers to a specific patient’s care in the home, e.g., teaching infection control procedures during an introductory visit or demonstrating comfort measures for the patient in his/her home. They can also count the time that they are training a volunteer to do a particular administrative task (clerical duties in the office.) But in computing the level of activity, the hospice should not count the hours that they spend in the general orientation and training about hospice philosophy, employee issues, or education support meetings.

    GS Comment: I believe the two paragraphs above are key to your question. While CMS states that the volunteer program must be of sufficient size to provide administrative or direct patient care, it specifically states that there must be at least the number of volunteer hours equivalent to 5% of "total patient care hours of all paid hospice employees and contract staff." Administrative tasks must relate to patient care. For example, volunteering at fundraising events or being a member of the board of directors does not apply.

    The HHS guidelines above state that some patient care training could be considered applicable, but it must apply to a specific patient. For example, if a patient requires specific care or consideration, a staff member can go with the volunteer and instruct them on the special circumstances. However, regular training of volunteers that is not patient specific cannot be included.

    Similarly, administrative training relating to patient care can be included. What cannot be included is further clarified in the HHS guideline as "the hospice should not count the hours that they spend in the general orientation and training about hospice philosophy, employee issues, or education support meetings."

    A related CoP that may provide additional insight in this regard is related to cost savings calculations because it highlights some of the ways volunteers are used.

    The CMS Conditions for Participation (CoP) §418.78(d) Standard: Cost Saving, states:

    "The hospice must document the cost savings achieved through the use of volunteers."

    HHS Guidelines state:
    It is anticipated that the hospice will use volunteers to supplement the care being provided by the paid staff who work directly with patients and their family members, both in the patients’ home and the inpatient setting.

    The cost savings achieved through the use of hospice volunteers is computed from the time that the hospice’s volunteers spend in administrative support or direct patient care activities. Administrative support means support of the patient care activities of the hospice (e.g., clerical duties in the offices of the hospice) and not more general support activities (e.g., participation in hospice fund raising activities.) The time volunteers spend attending education/support meetings would not be included in computing the cost savings.

    GS Comment: You should be aware that the hours calculated in the 5% are not necessarily applicable to the Cost Savings calculation.

    Hope that is helpful.

    Greg Schneider
    President, HVA
    HCF Creator

    *** Please Note ***
    No information contained in this discussion is legal advice, nor is it intended to be. Your hospice should consult an attorney for individualized advice regarding its own situation and interpretation of the applicable HHS regulations.
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