Center to Advance Palliative Care

I would review the Conditions of participation guidelines for hospice before trying to use the hospice staff to provide services in the nursing home. You would not be able to bill for either the chaplain or MSW services and this would be taking them away from their primary hospice responsibilities. They would need to be paid out of two distinct cost centers so that there would not be a conflict of interest or violation of Stark and other laws. You could consider developing a collaborative relationship with the chaplain and the MSW in the facility and see about getting a commitment from the facility to have those staff develop skill and expertise in providing palliative care services. You could then regularly interact with them, establish the plan of care with them and nursing. In that scenario, they would remain on the facility's budget. Sharol Herr, RN, MSEd; Nurse Clinician/Education Coordinator; Mount Carmel Health Palliative Care Leadership Center; Columbus, Ohio.