TX

I agree that residents would benefit from improved communication between LTC and Hospice providers. However, as a LTC facility Director of Nursing that works diligently on a daily basis to collaborate with local Hospice agencies, I disagree with the increased responsibility placed on the LTC facilities under this proposed rule. I find it challenging to get information from local Hospice providers in a timely manner. I coordinated a weekly Hospice meeting at my LTC facility to improve communication, yet hours after the meeting my nurses will receive orders that were not discussed at the meeting and often that contradict what was agreed upon by Hospice and LTC staff at the meeting. There is often disagreement between Hospice staff and LTC facility staff due to Hospice providers changing orders that are unrelated to the terminal diagnosis or palliative care. Hospice physicians do not communicate directly with LTC nurses and rely on reports of Hospice nurses that rarely see residents with no input from the staff responsible for 24 hour care. The Hospice providers are not willing to provide rationale for orders and this makes it difficult to support changes when family members or residents question the LTC staff. It would be helpful if there was a standardized communication form that Hospice providers would submit to notify LTC staff of new orders, changes, etc. and if it indicated whether or not the primary physician and family member had been notified. A similar form could be utilized for LTC facilities to notify Hospice providers of changes. LTC nurses often call primary physicians to notify of changes in orders and are told that they did not approve this and given orders to change it back. LTC nurses are then caught between Hospice and primary physicians and spend an unnecessary amount of time trying to sort out the plan of care. This takes time away from other residents, other patients of the primary physician and other Hospice patients.