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NHPCO Regulatory Requirements for After-Hours Triage

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Recently, National Hospice and Palliative Care Organization (NHPCO) Director of Regulatory and Compliance, Jennifer Kennedy, issued a clarification on the use of after-hours on-call services. The Director reminded NHPCO members that under the federal hospice Conditions of Participation (COP), hospices must routinely provide substantially all core services, including nursing services, directly by hospice employees such as patient assessments, care planning, updates to the plan of care, and in-person visits.

The NHPCO Regulatory Director had three key recommendations:

  1. Make sure your hospices still employ and assign a sufficient number of on-call nurses who can meet the 24/7 nursing needs of their patients.
  2. Work with your vendor to establish procedures to ensure that answering service personnel are not replacing the role of the hospice’s employed on-call nurses.
  3. Have the ability to demonstrate, through procedure and documentation, that the nursing needs of your patients are being met by hospice-employed nurses.

We welcome the NHPCO Regulatory Director’s comments because there has been confusion in the industry about the use of telephone triage services. AfterHours Triage (AHT) provides telephone triage for hospice organizations nationwide with a team of registered nurses experienced in hospice care.

Condition of Participation & Coordination of Services

Our registered nurses triage patient/caregiver calls over the phone, gathering necessary information, setting realistic expectations, and contacting the on-call nurse when necessary, based on the organization’s own protocols and procedures. We do not provide professional nursing services as described in 42 C.F.R. §418.56.

Plan of Care & Core Services

As mentioned previously, our registered nurses do not attempt to provide any core services, as described in 42 C.F.R. §418.64, by making patient assessments, or updates to a plan of care. Your IDG will continue to be responsible for directing, coordinating, and supervising the care and services provided by your staff.

Staffing Shortages

Staffing for after-hours care can be challenging based on your changing census numbers. AfterHours Triage extends affordable triage that can be scaled, based on your demand. In the past, some organizations interpreted that using after-hours on-call services was only allowed if they couldn’t reasonably staff on their own, based on CMS Regulations. This clarification may now help hospices that are in need of staffing resources to overcome this challenge in the industry. One of our clients used AfterHours Triage to help bridge the gap when facing “a perfect storm” of staffing changes that left them short-handed. Read the “Busy Hospice Provider Overcomes Staffing Crisis” Case Study.

Benefits of AfterHours Triage

Our services provide two primary benefits for our clients: 1) improving the patient and caregiver experience because they now have a registered nurse as their first point of contact when the office is closed, and 2) improving the staff experience because they now have a buffer of support that allows them to get their needed rest. These benefits bring value in numerous ways:

  • High patient satisfaction brings optimal Medicare reimbursements and referrals
  • Patients/caregivers who get to speak with a registered nurse immediately are often diverted from calling 911 or heading to the ED
  • Reducing the number of interruptions an on-call nurse receives when the office is closed helps to avoid staff burnout and staff turnover; a very costly dilemma
  • In some cases, we are able to reduce the number of nurse visits needed through our effective triage

We want NHPCO members and hospice and palliative care providers to know that AfterHours Triage does not attempt to replace core services staff. We strive to complement, support, protect and assist in helping each organization achieve their goals in providing the richest experiences for their patients, caregivers and staff.

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