The eighth United States President was Martin Van Buren. He once said, “It is easier to do a job right than to explain why you didn’t.” Although this quote is over a century old, it is oh so true. Hospice directors are held accountable for the work of their staff. Through the eyes of the governing hospice board, “the buck stops” with the director. The following questions and answers may be helpful to hospice directors who have nurse aides, otherwise known as hospice aides, on their staff and want to prevent unpleasant surprises when surveyors visit.

Has the nurse aide had hospice training?

North Carolina Hospice Licensing Rules (Licensing Rules) require nurse aides to complete a training and competency program and be listed on the Nurse Aide Registry at the Division of Health Service Regulation. The Licensing Rules also require all hospice staff to participate in a minimum of eight hours of training and specifies the topics that must be included in the training. 10A NCAC 13K.0402(a).

Is the nurse aide competent in the duties he/she is expected to perform?

The North Carolina Nursing Practice Act and its corresponding regulations require Registered Nurses (RNs) to be accountable for validating the qualifications of personnel delivering care. The Hospice Conditions of Participation (CoPs) and Licensing Rules also require the RN to validate competency.

Is the nurse aide on the Nurse Aide Registry?

Supervisors must ensure that nurse aides are listed on the Nurse Aide Registry, which ensures that the nurse aide has met the minimum training and competency requirements. The nurse aide must still complete the hospice training referred to in the answer to the first question above.

Are supervisory visits being done at least every 14 days?

Licensing Rules and the CoPs require that an RN make an on-site supervisory visit to the patient’s home at least every 14 days, with or without the aide’s presence, to assess the care and services provided by the nurse aide, assuming such services are being provided. Surprisingly, this is one of the top 10 hospice survey deficiencies found by federal surveyors.

Has the nurse aide annual on-site visit been completed?

The CoPs also require that an RN make an annual on-site visit to the location where a patient is receiving care in order to observe and assess each aide while he or she is giving care. 42 CFR 418.76(h)(2).

Is the nurse aide following the care plan?

Both the Licensing Rules and CoPs require that hospice services be provided in accordance with the plan of care. The scope and frequency of the nurse aide visits must be detailed in the plan of care; failure to do so is a frequently cited survey deficiency.

Does the nurse aide meet the continuing education requirements of 12 hours during each 12-month period?

The interpretive guidelines allow some flexibility with this requirement. It may be a calendar year, employment anniversary basis or a rolling 12 month basis. Individual agency policy will direct how this regulation is accomplished.

Are the nurse aides’ personnel files kept current with all content requirements met?

Licensing Rules clearly define the content requirements of personnel records. 10A NCAC 13K.0401(d)(1)-(9).

It is clear from these questions and answers that there are a number of regulatory requirements hospices must meet in order to effectively provide and supervise nurse aide services. You should incorporate some of these questions into your Quality Assessment Performance Improvement program and monitor your compliance with these requirements. When thinking back to what President Van Buren said many, many years ago, hospice directors may wish to put forth the extra effort to get it right now, instead of having to explain later why it wasn’t right.