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

The Virginia Association for Hospices & Palliative Care represents the majority of Virginia's hospices and we recommend that the following section be repealed:  12VAC5-391-330B --  ‘The medical director shall have admitting privileges at one or more hospitals and nursing facilities that provide inpatient service to the hospice program's patients.’  

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.

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

Blue Ridge Hospice is a not for profit community based hospice serving 8 counties in the Shenandoah Valley, Warren, Loudoun and Clarke counties.  We care for over 200 patients a day and provide inpatient hospice care at our 8 bed inpatient facility in Winchester, Virginia.  On behalf of my board, medical directors and staff,  we recommend that the following section be repealed:  12VAC5-391-330B --  ‘The medical director shall have admitting privileges at one or more hospitals and nursing facilities that provide inpatient service to the hospice program's patients.’  

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.

Thank you

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.

Since the hospitalist role came about in our local community around 2014, there are very few physicians left who admit to our one local hospital. I don't see how small,rural hospice agencies will be able to meet this regulation with the current lack of physicians in general. Thank you for the opportunity to express my opinion on behalf of myself, our IDG, and our Board of Directors.

As the CEO of Crater Community Hospice located in Petersburg,VA, I have reviewed the current regulations. I request that section 12VAC5-391-330B be removed.  As others have noted, the hospitals in my service area no longer have attending physicians seeing the inpatients. Hospitalists cover 24/7 and the hospice Medical DIrector consults with him/her regarding symptom management. The facilities work with specific physicians who come into their buildings. The hospice Medical DIrector oversees the care of our patients and will consult as needed.  Thank you for the opportunity to comment. 

I  have entered my comments previously but my organization name  did not show on the comment. 

Thank you for the opportunity to comment on the Regulations for the Licensure of Hospices.  I request that the requirement that the hospice "medical director have admitting privileges at one or more hospices and nursing facilities that provide inpatient services to the hospice program's patients" be removed from the regulations. Most hospitals and facilities have hospitalists and medical directors who provide services to patients, including hospice patients, and have eliminated the role of the attending physician.  Despite this change in roles, the quality of care provided to hospice patients during an inpatient stay has not been not jeopardized, as hospice medical directors are still able to provide valuable input into the patient's inpatient plan of care.   

Thanks for the opportunity to comment on the Regulations for the Licensure of Hospices.  I am requesting that the requirement that the hospice "medical director have admitting privileges at one or more hospices and nursing facilities that provide inpatient services to the hospice program's patients" be removed from the regulations. Most hospitals and facilities have hospitalists and medical directors who provide services to patients, including hospice patients, and have eliminated the role of the attending physician.  Despite this role change, the quality of care for hospice patients during an inpatient stay has not been not jeopardized. Hospice medical directors are still able to provide valuable input into the patient's inpatient plan of care. 

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

VITAS Healthcare, who operates a Medicare Certified hospice program in northern Virginia, recommends the following section be repealed:  12VAC5-391-330B --  ‘The medical director shall have admitting privileges at one or more hospitals and nursing facilities that provide inpatient service to the hospice program's patients.’  

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.