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Introduction
Over the last decade, the role of the medical director has become increasingly defined. Federal and state regulations as
well as corporate entities have contributed to this process. AMDA has led the way in developing and refining this role.
All will agree that the administrative responsibilities as well as the liabilities of the long term care medical director have
continued to increase. Yet the need for ancillary and consultative care continues, increasing these responsibilities and
liabilities.
The medical director's role in quality end -of-life care is no exception. The Medicare Hospice Benefit has been identified
within the long term care facilities as a six month entitlement to Medicare patients who meet specific criteria. However,
the multitude of hospice providers has created a variability in the quality of care delivered. Despite the favorable final
Office of Inspector General (OIG) report on Hospice in the Nursing Home released in April, 1998, there are still concerns
of fraud, duplication of services, reimbursement and prognostication dilemmas. Some of these issues have been
addressed, but the concerns of the nursing home medical director have not been covered extensively.
The responsibility of quality medical care throughout the facility rests on the medical director more than ever before. As a
result, the Hospice Subsection has chosen to address the integration of hospice and long term care. The following
concerns were discussed and approved by the Subsection at the 1999 Annual Symposium of the American Medical
Directors. The goal of this document is to enhance the delivery of quality care to nursing home hospice patients by
clearly delineating the role of the medical director.
Quality Assurance
The medical director of a nursing home has to include end -of-life care in the Quality Assurance (QA) process. As a
result, several issues need to be evaluated, measured, and trended. These potential areas are listed to serve as ideas to
be considered. Over a period of time, the data that are reported to the QA committee will help to establish benchmarks.
Pain Management
Pain has been defined as the 5th vital sign and can be measured by several different instruments. The choice of a visual
acuity graph is not as challenging as the accurate assessment of pain. There continues to be a lot of concern on how
best to accurately measure pain and discomfort, especially in the non -communicative and/or demented patient. Better,
more comprehensive evaluation tools have been created, examples of which are included with this paper. (Appendix A)
Another useful measurement is the length of time it takes to control pain symptoms. Also, the utilization of the various
pain medications as well as the various routes of administration could be measured. The committee could measure
separately the management of different types of pain including chronic pain, acute pain, or pain found in actively dying
patients.
A Pain Burden Scale is calculated by dividing the number of patients in the facility in pain by the total number of patients.
(Appendix B) The QA committee could require this information from various hospice providers as well as monitor the
data for their own facility.
Hospice Utilization
Knowing the average length of stay for patients receiving hospice care within the facility, as well as the average length of
stay of the hospice program for the city, state, or region could be beneficial. This would address some of the current
concerns by many regarding the hospice/nursing home integration and the qualification for the patient's six month
entitlement. The QA committee can monitor the percentage of patients on hospice in relation to the facility census.
Furthermore, the number of patients on hospice in the facility can be measured against the total number of facility
patients. The terminal patients are those who are in persistent vegetative state, those who have end stage medical
condition, or whose death is imminent.
Bereavement
Bereavement in the nursing home includes the family, staff, friends, and fellow patients and is ongoing. Bereavement
services includes routine support to those in need as well as memorial services. Documentation for these duties is
needed. Several tools could be utilized to meet the facilities needs. (Appendix D)
Further Documentation
Some surveyors have requested documenting and reestablishing the surrogate's understanding of the patient's advance
directives and the end -of-life care being provided. The issues such as malnutrition, tube feeding, pressure ulcers, or non -
hospitalization needs to be discussed again and documented every 60 days. The hospice provider, nursing facility, and
attending physician need to address these issues.
Surveys
Satisfaction surveys from the patients and families are useful and should include information regarding the nursing home
staff, medical director, and attending physician. Performance surveys may be beneficial, where the proposed care plans
can be compared with the care actually given. It is critical that the coordinated plan of care for these patients be written
as specific as possible.
In-Service Education
Coordinated in -services need to be given to meet the specific educational needs of each facility.
Minimum Data Set (MDS) Whether the MDS is the most appropriate assessment tool in the nursing home has
continued to be debated. The patient's care plan is produced from this assessment tool and the MDS triggers that refer
to the appropriate Resident Assessment Protocols. The MDS is now electronically transmitted and it is now used to
determine outcomes. Finally, PPS has utilized the MDS in establishing the reimbursement rate for the skilled units.
However, the MDS has shortcomings. It is designed as a functional assessment tool with expected outcomes for
maintaining or improving function. With good end-of-life care, patients may decline in their ability to function. In addition,
the MDS does not address all of the areas needed for end -of-life care including psychological, social, and spiritual
issues.
The Hospice Subsection recommends that a separate instrument be developed utilizing the MDS format. The hospice
provider should be responsible for the completion and utilization of this separate assessment tool, since the palliative
care plan needs to be determined by those trained in palliative care, and not just acute and rehabilitative care. HCFA has
now requested that such an instrument be developed. Several groups have already started on parts of this project
including the National Hospice Organization and the Hospice Nursing Home Task Force.
Fraud
Several areas of potential fraud need to be addressed. Ethical concerns usually revolve around reimbursement issues.
As a result, a chart has been developed to help answer most of these questions. (Appendix E)
Further reimbursement issues relate to medical director fees. As in any area of long term care, these rates are not in any
way related to ability to refer patients, or tied to any performance clauses. There has been recent concern relating to dual
medical directorships where a physician functions as both a nursing home medical director as well as a hospice medical
director. If the purpose of the dual medical directorship is for referrals, then this remains unethical. If the purpose for dual
responsibility is for education, integration, continuity of care, regulatory compliance, etc. then there are not any ethical
issues.
The OIG has regularly published fraud alerts. Areas pertaining to long term care include concerns over inducements by
hospice providers. Medicare skilled units were targeted because hospices provided free services to these residents in
order for them to contract with the hospice when discharged. However, if a hospice patient has a hospitalization
unrelated to the terminal diagnoses and qualifies for Medicare skilled care, they can remain on hospice related to their
terminal diagnosis.
The National Hospice Organization's development of prognostication guidelines, especially of the non -malignant
diseases has helped defray many of the eligibility concerns. Physicians can utilize these and other similar documents to
avoid non -eligible admissions. (Appendix F)
Medical Directors
Nursing Home
The responsibilities of the nursing home medical director have already been established. However for completeness, a
copy of recommendations by AMDA has been included. (Appendix G) Nevertheless, the involvement of the nursing
home medical director in the hospice program is worthy of mention. The nursing home medical director as well as the
attending physician should stay involved in the patient care.
This can be done in several ways. The attending physician should continue as the primary care provider for his patient. If
the physician is not working for the hospice, they can bill Medicare for their service as usual. A chart demonstrating the
reimbursement issues is attached. (Appendix E) If the attending feels uncomfortable or unsure about the palliative care
needed for the patient, such as appropriate symptom interventions, he can always consult with the hospice medical
director. The nursing home medical director should be in contact with the hospice medical director if any concerns or
problems develop. Attendance at the hospice interdisciplinary team meeting (IDT) might be appropriate, especially if
there are issues to be addressed or discussed concerning the hospice program within the nursing facility. The nursing
home medical director may need to explain and train the hospice on certain nursing home regulations and needs or how
simple grievances or concerns could be addressed. A good working relationship is always encouraged.
Hospice
The hospice medical director should embrace a multitude of duties and responsibilities. Since many nursing home
medical directors are considering hospice medical director positions, the Hospice Subcommittee has chosen to delineate
some recommendations.
1. Confirm the diagnosis and prognosis for each newly admitted patient.
2. Visit patients as indicated.
3. Recertify patients for each benefit period
Education
1. The hospice medical director should be trained and well versed in palliative care. Education in these areas can be
obtained at the AMDA annual symposium, the American Academy of Hospice and Palliative Medicine (AAHPM)
meetings, National Hospice Organization (NHO), Hospice Association of America (HAA), as well as other national
organizations.
2. The hospice medical director should develop and present educational materials at in -services for hospice, nursing
home and hospital staff. Topics are to include but not be limited to:
a. Pain management
b. Symptom management
c. End -of-life decision making
d. Medical ethics
e. Hospice Medicare regulations
f. Palliative care
Marketing
The hospice program can be represented to physicians, medical community, medical facilities, and the community
through articles, presentations, or videos.
Administration
Clinical Duties
1. Be available to serve as a consultant expert in palliative care. These duties may include:
a. In -patient rounds
b. Nursing home rounds
c. Home visits
d. On call
e. IDT meetings
Frequently Asked Questions
1. How can you tell when a patient has six months or less to live in order to qualify for the Medicare hospice
benefit?
The regulations state that a patient can qualify for hospice if the patient is in the last six months of life "if the terminal
disease runs it's normal course."
No one has a "crystal ball". Therefore, HCFA has revised the benefit periods for recertification of the patient's terminality,
if a disease does not run it's "normal course".
To help with prognostication of non -malignant terminal disease, the National Hospice Organization (NHO) published the
GUIDELINES FOR PROGNOSIS OF SELECTED NON -MALIGNANT TERMINAL DISEASES. (Appendix F) These
guidelines are available to address end-stage prognostication of Dementia, Heart Disease, Pulmonary Disease, Liver
Disease, Renal Disease, Coma, HIV, ALS, and Stroke.
In the past there were four benefit periods, (90, 60, 30 days, then a fourth period that was unlimited). At each period the
physician recertified that the patient had 6 months or less to live. Many patients had entered their 4th benefit period and
were in fear of losing their hospice benefits, if they were to remain on hospice till they died.
Since the end of 1997, the benefit periods have been revised. Now the patient has 90, 90, then continuous 60 day
benefit periods for physician recertification of terminality. For example, if a patient improves and is not felt to be terminal
at the end of the 2nd benefit period, then the patient can come off of hospice care and be restarted when the patient's
prognosis worsens again.
If the attending physician is not salaried by the hospice that is caring for that patient, Medicare is billed for the level of
service provided.
If the physician is employed by the hospice caring for that patient, the hospice is billed for the level of service provided.
If the physician is salaried by a different hospice , and not by the hospice caring for the patient, Medicare is billed for the
level of service provided.
If an associate sees the patient, he/she must bill Medicare or the hospice under the primary care physician (attending
physician of record) name and provider number and then be reimbursed by the physician. HCFA receives a record of the
name of each attending physician for each hospice patient.
4. Is hospice care and nursing facility care a duplication of services, ('double -dipping')?
Hospice began as caring for the dying patient at home. The family would provide the daily care for the patient, bathing,
feeding, toileting, giving medicine, etc. Hospice would provide specialized services of pain management, non -pain
symptom management, psychosocial, spiritual, and bereavement care for up to one year. Literature has established the
value -added benefit of hospice to improve the quality of end -of-life care in this setting.
In 1986, the nursing home/facility was recognized as a surrogate home for America's elderly, and that hospice care was
a patient right in this new home setting. Now the nursing facility provides the daily care for the patient, i.e., bathing,
feeding, toileting, giving medicine, etc. Hospice would provide the same service as in any other home setting. The affects
on the quality of end-of-life care in this setting have not been published.
5. What CPT codes should a physician use when seeing a hospice patient in the nursing facility setting?
According to the Health Care Financing Administration and American Medical Association's CPT Information Services,
"there are no specific CPT codes for evaluation and management services provided by a physician to a patient receiving
hospice care in any location. When a Medicare beneficiary elects the hospice benefit, Medicare pays the hospice for all
services related to the terminal illness through four set per diem rates. The exception to this is physician services.
General supervisory services and participation in the establishment, review, and update of plans of care provided by the
hospice medical director or a physician member of the hospice interdisciplinary team are included in this hospice per
diem. This would include evaluation and management services provided by a physician employed by, or providing
services under arrangement with, the hospice."
"Medicare hospice regulations, at 42 CFR 418.304(c), state that services of the patient's attending physician, who is not
employed by the hospice or providing services under arrangements with the hospice, are not considered hospice
services. These services are billed directly to Medicare Part B according to procedures established in 42 CFR 405
subparts D and E. When provided by an attending physician, as described above, evaluation and management services
provided to hospice patients would be billed in the following manner:
n If the evaluation & management services are provided to a hospice patient that is residing in a nursing facility,
then the subsequent nursing facility care codes are billed (99301-99316 series).
n If the evaluation & management services are provided to a hospice patient in their private residence, then the
home services codes are billed (99341-99350 series). The physician must provide the evaluation & management
services in the patient's home in order for these codes to be billed.
n If the evaluation and management services are provided to a patient in a board and care type facility, including a
hospice residential facility, then domiciliary/rest home codes are billed (99321 -99333 series). Again, these
services must be provided in the facility in order for the domiciliary/rest home codes to be billed."
End-of-Life Care Resources for Additional Information
Choice in Dying
1035 30th Street, NW
Washington, DC 20007
202/338 -9790
202/338 -0242 fax
www.choices.org
WHEREAS, one-third of all residents entering a nursing facility will die within 12 months
of admission, and
WHEREAS, the care planning process for residents dying in nursing facilities require
coordination of resources, and
WHEREAS, the medical director’s involvement extends to all services provided in the
facility related to end-of-life care, therefore be it
RESOLVED, that AMDA recognizes the significance of end-of-life care planning. And,
that all residents in nursing facilities should have access to appropriate end-of-life care.
The expected outcomes are respect for patient advanced directives, safe and
comfortable dying, and effective grieving, and
RESOLVED, that medical directors should be provided with sufficient training, education,
and institutional involvement to assess and improve end-of-life care in the facility.
______________________________________________________________________
No pain
NUMERIC RATING SCALE
20
19
18
17
16
15
14
13
12
11
10
9
8
7
6
5
4
3
2
1
0
VERBAL DESCRIPTOR SCALE
_____ No pain
VERBAL NUMERIC ANALOG SCALE
Subject is asked:
On a scale of 0 to 10,
Resident________________________________________ Room_______________
Date__/__/____
Diagnosis________________________________________________________________
Allergy_________________________________________________________________
Verbalize pain
Y=yes N=no
Description
A=Achy F=Stabbing
B=Dull G=Throbbing
C=Sharp H=Radiating
D=Upon movement I=Burning
E=Upon touch J=Itching
Frequency of Pain
A=Daily
B=Pain less than daily
Time of Pain
A=Morning E=Bedtime
B=Afternoon F=All times
C=Dinnertime G=Intermittent
D=Evening H=Night
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
APPENDIX B
PAIN BURDEN SCALE
Example
40/100=0.4
08/17/00
APPENDIX C
SYMPTOM ACUITY GRAPH
PATIENT:_________________________ MR#________________
Month________ Year_____
Rank severity from 1 to 10, filling in the number of boxes
Date
10
9
8
7
6
5
4
3
2
1
Initials
Date
10
9
8
7
6
5
4
3
2
1
Initials
Date
10
9
8
7
6
5
4
3
2
1
Initials
Symptoms (Record symptom and rank 1-10)
1. Pain 2. Nausea 3. Dyspnea 4. Constipation 5. Sleep 6. Edema
7. Confusion 8. Depression 9. Other________________
SYMPTOM ACUITY GRAPH
PATIENT: Jane Doe MR# 107925
Month Feb Year 2000
Date
10
9
8
7
6
5
4
3
2
1
Initials
Date
10
9
8
7
6
5
4
3
2
1
Initials
Symptoms (Record symptom and rank 1-10)
1. Pain 2. Nausea 3. Dyspnea 4. Constipation 5. Sleep 6. Edema
7. Confusion 8. Depression 9. Other________________
APPENDIX D
BEREAVEMENT SERVICES DOCUMENTATION
Due Done
Standard Care – Level One – Low Risk
Bereavement Services Declined: __________________________
Bereavement Card (Completed 1 week after DOD by IDG team) _________ _________
Not able to contact letter sent _________ _________
Transfer to Bereavement (Completed by RN after death) _________ _________
Bereavement Assessment/Plan of Care (1st month after death) _________ _________
Introduction letter and satisfaction survey (1st month after death) _________ _________
Quarterly Newsletter Refer to Bereavement Notebook
Invitation to Grief Group Refer to Bereavement Notebook
Invitation to Memorial Service Refer to Bereavement Notebook
Other:__________________________________ _________ _________
Level Three – High Risk (In addition to Level One and Level Two
Further Follow-Up Calls when deemed appropriate _________ _________
_________ _________
_________ _________
_________ _________
Comments/Observations/Interventions _______________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________
_______________________________________________________ _____________________
Staff Signature Length of Visit
APPENDIX E
Billing Guidelines
Care Care provided Care provided Care provided by Care provided Care Care Care
provided by by non- by non- physician who has by a physician provided provided by provided by
primary hospice hospice provided a performing by hospice the hospice physician
physician primary primary second opinion to diagnostic/ physician physician’s taking call
who is not a physician’s physician’s on- the patient therapeutic associate for the
hospice associate call associate procedures hospice
physician physician
Care Bill Medicare Bill Medicare Bill primary Bill hospice after Bill hospice Bill hospice Bill hospice Bill hospice
related to under primary physician, who authorization after physician,
the physician’s in turn bills given authorization who in turn
terminal name Medicare given bills hospice
illness
Care Bill Medicare Bill Medicare Bill Medicare Bill Medicare Bill Medicare Bill Bill Medicare Bill Medicare
unrelated Medicare
to the
terminal
illness
APPENDIX F
NHO PROGNOSTICATION GUIDELINES
TABLE OF CONTENTS
The physician medical director should establish a job description, after consulting with a facility’s
administrator and director & nursing.
1. In collaboration with the nursing director, the administrator, and other health
professionals develop formal patient care policies for the facility that:
• provide for the total medical and psychosocial needs of the resident, including
admissions, transfer, discharge planning, range of services available to resident,
emergency procedures, and frequent of physician visits, in accordance with resident
needs;
The medical director should help the facility ensure that these patient care policies are carried out,
as reflected and documented in a facility’s drag regimen review and quality assurance committee
activities.
2. Act as liaison between the attending physicians and other health professionals caring for
residents.
4. Develop, amend, recommend and implement appropriate clinical practices and medical
care policies that help insure that each patient’s medical regime is incorporated
appropriately into the plan of care.
6. Monitor the clinical practices of attending physicians, and intervene as needed on behalf
of patients or the facility’s administration.
7. In cooperation with the administration and with the approval of the governing body,
represent the medical staff in developing rules, regulations and policies for the attending
physicians who admit their patients to the facility.
8. Review recommendations and reports of drug regimen review and quality assurance
activities, and take appropriate and timely action as needed to implement
recommendations.
9. Meet periodically with nursing and other professional staff to discuss clinical and
administrative issues, specific patient care problems and professional staff needs for
education or consultants, offering solutions to problems and identifying areas where
policy should be developed.
10. Help obtain the services of qualified professionals to serve as consultants to help meet
residents' special needs, such as dentistry, podiatry, dermatology, or orthopedics.
11. Help the facility administrator and professional staff ensure a safe and sanitary
environment for residents and personnel, by: reviewing incidents and accidents,
identifying hazards to health and safety, and advising about possible correction or
improvement of the environment.
1. Attain and provide information about federal, state and local regulations and codes
applicable to long term care facilities, applicable of the Joint Commission on
Accreditation of Healthcare Organizations (JCAHO), and the professional service and
administrative requirements and expectation of third party payers.
2. Help develop in-service and other education programs and materials for attending
physicians and professional staff within the institution, in cooperation with the director of
nursing and the administrator.
3. Provide current information and advice about patient care, new treatment modalities, and
the pathophysiology of illness.
4. Prepare a periodic report for administration summarizing his/her actions, concerns and
recommendations as medical director.
5. Represent the facility in discussions and meetings with other institutions or agencies on
issues relevant to medical care.
6. Help the facility develop an ongoing program to evaluate and manage the health of the
facility's employees, by 1) establishing policy and procedures, and 2) direct physical
examination of employees, emphasizing freedom from significant infection, pre-
employment physical examinations and reexaminations, and compliance with local and
state health regulations.
7. Help manage review and respond to federal, state or local surveys and inspections.
This document is a recommended job description for a medical director. It can be used as a guideline for
administrator and physician, provided the terms and provisions of the document are modified to apply to
the specific scope and resources of each individual situation.