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This is a very difficult question. I asked Rodney Tucker, MD, at the PCLC at UAB, to respond and he was kindly able to offer this answer to your question.
Best,
Mike Rabow, MD
PCLC at UCSF
Rodney's Response:
1) Designation of the palliative care beds may vary by institution and by state CON if those beds are considered acute care or "hospice" beds. Most facilities either have a dedicated geographically separate unit or they have an inpatient hospice dedicated unit (managed by a hospice) or they have a virtual unit or swing beds within the facility where the patients are no longer on DRG or regular per diem but instead they are on their hospice GIP benefit.
2)Some states will not allow beds to be designated as hospice beds unless there is a CON process which takes those beds out of that hospitals acute care compliment. Many hospitals are simply "leasing space" to hospices for units, etc.
3)Billing follows suit as to who is the payor. If truly palliative care and not on hospice benefit then billing remains part of the DRG or the regular payor per diem like Blue Cross Blue Shield. These patients are essentially still acute care patients.
4)Beds to not have to be in a long term care unit and I think that is actually a little more complex.
5)CMS mortality is a VERY even more complicated. But the bottom line is "switching patients" in the hospital from acute to hospice GIP while they remain in the same bed may and likely will not help mortality on that patient unless 1)Patient previously on hospice, 2)patient switched on day one of the admit, or 3) they are switched and moved out of the hospital and live 30 additional days. Switching payors for these patients is not a tried and true way to decrease hospital mortality for CMS if you look at the true data.
Hope this helps.
Rodney