The Rev. Steve Rice on proposed reforms for spiritual care

HOSPICE Spiritual Care Providers….This is for YOU!

The CMS (The Centers for Medicare and Medicaid Services - a Federal agency within the U.S. Department of Health and Human Services) recently issued proposed reforms to the Medicare Benefit that will affect how spiritual care is provided in hospice organizations.

As Chaplains/Spiritual Care providers in hospice we are invited to review the new proposals to the Conditions of Participation (COP) and make comments to a federal committee by July 26, 2005.

Click HERE to download a pdf file.

Highlights of Proposed Changes for Spiritual Care:

1. I believe the most significant proposed requirement in hospice will be the inclusion of Spiritual Care Counseling services as a CORE SERVICE (Proposed 418.64, page 30850, 51). Spiritual counseling joins the medical and “medical social services” disciplines as essential and required in hospice assessment and delivery of hospice/palliative care. What does this mean? I serve a hospice with a census of 200. Over one year ago we provided spiritual care to those patients and families based on the referral of our nurses or social workers. We followed 30-35% of the caseload. In this past year we began viewing spiritual care as a core service and assumed an initial assessment by a professional spiritual care provider. As a result of this change in philosophy, today we follow 85 to 90% of our patients and families. That is the good news. The bad news is we have not yet increased our number of spiritual care providers. Spiritual care is an essential part of dying. Now Medicare is saying we agree.

2. A second area to note is the section preceding the Core Services (pages 30844-30851) Basically, spiritual care has to be part of the individualized plan of care, assessment and outcome measure. The assessment needs to be completed in four calendar days after the patient elects the hospice benefit! (page 30845)

3. The weakest section has to do with Personnel Qualifications for Licensed Professionals (418.114, page 30859). The Committee, working with NHPCO, has a difficult time defining the qualifications for a professional spiritual care counselor/chaplain for hospice. One sentence does state “these [professionals] must be licensed, or certified or registered to practice by the State …” It is easy to define a state licensed individual (social worker or speech pathologist) or a certified nurse. Here is an area where we can educate the Committee as well as hospice and palliative care programs. If I interpret these qualifications correctly, then a salesperson friend, who, for fun, bought an M.Div. for ten dollars on-line and registered as a licensed minister in this state, is as qualified as I am to provide spiritual care in hospice.

How To Contact:

The Federal Register gives reminders throughout that you can electronically (not fax) submit comments to httpp://www.cms.hhs.gov/regulations/ecomments by July 26th, 2005. Mention the section you are commenting on when making your remarks.

There are significant changes for hospice and palliative care (when they become Medicare eligible). You and your administrators need to be aware of how these proposed changes, if adopted, would affect what you do and how you do what you do.

Thanks to Sue Wintz for bringing this to our attention.

Note: These proposed rules are especially important as CMS states in this document that they are working to revise not only the hospice requirements but the requirements for other health care providers, such as hospitals, home health facilities, and others. The APC Board is submitting written comments to CMS regarding the proposed changes. Those comments as well as a model response for Board Certified Chaplains to use in their own submissions will be available on the APC website. For more information, contact the APC office at info@professionalchaplains.org or Sue Wintz, Chair, APC Commission on Quality Services at sue.wintz@chw.edu.

Do you have thoughts about advocacy you’d like to share with your colleagues? Send an e-mail to info@PlainViews.org.