Use of [Hospice] Volunteers

The Health Group

CMS waived the requirement for hospices to use volunteers (42 CFR §418.78(e)) during the Public Health Emergency (“PHE”); however, the requirement is again effective January 1, 2024.  Many hospices had difficulty complying with this requirement even before the PHE.

Hospices need to begin addressing this requirement immediately.  Rebuilding the volunteer base post PHE is not going to be an easy task for many hospices.  Hospices may be subjected to a standard level survey citation if they don’t meet the five percent (5%) of hospice patient care hours requirement.  A standard level deficiency means that the hospice is not compliant with one of the standards under a condition of participation.  The hospice remains certified with this type of deficiency but will need to submit a plan of correction to the surveying agency describing how the deficiency will be mitigated.

Hospices must capture Volunteer Coordination costs in the accounting records for inclusion in the Hospice Cost & Data Report.  If a Hospice employee provides volunteer coordination services and other services, the compensation should be segregated in the accounting records or appropriate information should be provided to that individual responsible for cost report preparation, allowing for any necessary reclassification of costs.

Additionally, the Hospice should capture the hours spent by volunteers into the following, at a minimum:

• Patient support – patient’s residence,
• General support – patient’s residence (housekeeping, meals, errands, etc.),
• Patient support – hospital,
• Patient support – SNF, long-term care,
• Administrative services support,
• Fundraising activities, and
• Bereavement.

A qualified cost report preparer, internal or external, should be able to reasonably allocate Volunteer Services Coordination costs on the Hospice Cost & Data Report based on this information.  Additional categorization of volunteer hours will further enhance the quality of the Hospice Cost & Data Report.