As COVID-19 continues to highlight the need for alternate care methods in healthcare, telehealth has been largely introduced across the industry to meet this need. However, many questions regarding how to monitor the effectiveness of a telehealth visit in the hospice setting and whether hospice care should be, or even can be provided in this manner have emerged.
With this new emphasis on telehealth, there’s much for hospice providers to consider. Let’s take a look at the following questions to determine the most effective way telehealth can be utilized for success in your organization.
How will you use telehealth (audio/visual) for your organization?
Since telehealth can only be conducted through audio and visual devices, consider which specific devices you should approve for staff use. Will staff use personal devices such as personal cell phones and laptops, or will they be using work devices assigned by your organization? Another aspect to consider is staff telehealth app usage. What app will be approved for use? How will you get the information coordinated with the patient? Is the app secure for use? See telehealth guidelines from HHS.gov for a list of approved telehealth apps that could be leveraged in your organization.
Do you have a plan for when telehealth is going to be used in lieu of a hospice onsite visit?
Although detailed policies and procedures are not required by accrediting bodies during the COVID-19 pandemic, hospice organizations should develop guidelines for staff to specify when telehealth should be used, and how telehealth should be used. Guide your staff also on what clinical elements you want covered during a telehealth visit and consider whether staff will be recording patient visits and adding them to your EMR, or if visits will only be documented and not recorded.
CMS has stated that they will “also allow hospice clinicians to conduct visits and provide services via telehealth as long as those activities are consistent with the patient’s plan of care.” For expectation details, see the Medicare and Medicaid Programs; Policy and regulatory revisions in response to COVID-19 Public Health Emergency. Make sure your staff understands that telehealth is not a one-size fits all solution for hospice care provided to patients and cannot substitute for all your onsite services. Again, clear guidelines should be in place for when telehealth should be used, and each patient scenario should be evaluated carefully to see if utilizing telehealth is appropriate. The use of telehealth must be documented within the plan of care.
How are you going to monitor the effectiveness of telehealth visits as they relate to meeting patient and caregiver needs?
The following are quality review considerations that can be used to monitor and audit the effectiveness of telehealth visits.
- Was the type of visit documented? In-person, telehealth or telephone?
- Was the plan of care updated to reflect telehealth/Telecommunication visits or frequency changes into the visit plan with beneficiary/representative agreement?
- Does the documentation indicate the patient needs are being met with the use of telehealth?
- Does documentation include COVID-19 education to the individual, caregivers (paid or in the home) and family? I.e., signs and symptoms, proper use of PPE, limiting visits
- Are the “COVID-19 vital sign” questions included? Has the patient had caregivers/others in the home who have been reported positive?
- What is the exposure potential with family members, including frequency of visits and travel? Is there a clear plan in place to monitor the patient for COVID-19 symptoms and instructions on when to call the hospice?
- Does documentation include descriptions of the patient and symptom management?
- If issues are reported by the patient or caregiver, is there a protocol on how follow-up visits or calls are to be documented and/or made?
Of course, all information is subject to change as CMS updates waivers and requirements regarding the COVID-19 pandemic, so providers need to pay close attention to updates as they become available.
CMS Guidance
Below are important revisions from CMS’s Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency that hospices should be aware of when incorporating telehealth into their operations.
§418.22 Certification of terminal illness.
- During a Public Health Emergency, as defined in § 400.200 of this chapter, if the face-to-face encounter conducted by a hospice physician or hospice nurse practitioner is for the sole purpose of hospice recertification, such encounter may occur via a telecommunications technology and is considered an administrative expense. Telecommunications technology means the use of interactive multimedia communications equipment that includes, at a minimum, the use of audio and video equipment permitting two-way, real-time interactive communication between the patient and the distant site hospice physician or hospice nurse practitioner.
§418.204 Special coverage requirements.
- Use of technology in furnishing services during a Public Health Emergency. When a patient is receiving routine home care, during a Public Health Emergency as defined in §400.200 of this chapter, hospices may provide services via a telecommunications system if it is feasible and appropriate to do so to ensure that Medicare patients can continue receiving services that are reasonable and necessary for the palliation and management of a patients’ terminal illness and related conditions. The use of such technology in furnishing services must be included on the plan of care, meet the requirements at § 418.56, and must be tied to the patient specific needs as identified in the comprehensive assessment and the plan of care must include a description of how the use of such technology will help to achieve the goals outlined on the plan of care.
For more information and guidelines on leveraging telehealth for hospice care, read Hospice: CMS Flexibilities to Fight COVID-19 or visit CMS.gov.
