Issue: Hospice Care in Assisted Living Facilities (ALFs) and Similar Facilities (added 3/20)

Question: Should hospice workers (including volunteers) be allowed access to nursing homes?

Answer: Hospice workers (including volunteers) have experienced challenges gaining entry to care for patients residing in nursing homes. Despite early CMS guidance to nursing homes indicating that hospice staff should be granted access (if passing a screening and using PPE properly), access continues to be denied. We are hearing of wholesale denial as well as access only being granted when the hospice patient is actively dying and/or when symptom management is needed. It may be helpful for hospices to share the guidance cited in the paragraphs below with the nursing homes as they clearly indicate that hospice staff should be allowed access to the nursing home if passing a screening and utilizing proper PPE. If there is a local or state order that is more restrictive than what is included in CMS guidance below, it supersedes this guidance.  NAHC is working towards a more direct statement on the issue from CMS.

CMS guidance states “hospice workers can enter a facility when using PPE properly,” and separate CMS guidance issued to hospice providers indicating the “If hospice care is provided in a nursing home, we have advised nursing homes that hospice workers should be allowed entry provided that hospice staff is following the appropriate CDC guidelines for Transmission-Based Precautions, and using PPE properly,” there were continuing issues with patient access.

CMS issued revised guidance to nursing homes on March 13 restricting all visitors to the facility, but specifying that hospice workers are among those excepted from the ban.

And, CMS stated in recent QSO memo on survey priorities: “CMS is aware that some providers (nursing homes, assisted living facilities, etc.) have significantly restricted entry for staff from other Medicare/Medicaid certified providers who are providing direct care to patients. In general, if the staff is appropriately wearing PPE, and do not meet criteria for restricted access, they should be allowed to enter and provide services to the patient (interdisciplinary hospice care, dialysis, organ procurement, home health, etc.).”

If hospice providers are not successful in getting facility access granted, it may be helpful to speak with the local and state officials regarding the prohibition.

Hospice agencies may also be able to revise the hospice plan of care for fewer visits, if appropriate.

For questions about telehealth visits, please see guidance here and here.