12VAC5-391-330B

Thank you for the opportunity to comment during the periodic review of hospice regulations.

Medi Home Health and Hospice has a number of community hospices throughout the state of Virginia. We are requesting the appeal of state Hospice regulation 12VAC5-391-330B.

Most community physicians, many of whom serve as hospice medical directors, are no longer allowed to have hospital or nursing facility privileges, as hospitalists and nursing facility medical directors have largely taken over the role of attending physicians.   Even without admitting privileges, hospice medical directors are well positioned to consult with hospital and nursing facility physicians for symptom management of hospice patients.