A good risk management program for healthcare facilities includes agreements that carefully address the coordinated care and services provided to patients by outside vendors or agencies.  Healthcare facilities that contract with outside staffing agencies, therapy companies, home health agencies, hospice, dialysis services, or other vendors may want to create a checklist for agreements to address the issues of coordinated care. For example, the checklist below is an example of a guide for senior living facilities that contract with hospice agencies.

Agreement contains what specific services the agency is to provide.

Agreement indicates how the services are:

  • Coordinated,
  • Supervised and
  • Evaluated by both the agency and the facility

Agreement stipulates any agency-related services that may performed by the facility staff and vice versa.

 Agreement delineates the role of the agency and the facility in the:

  • Admission process
  • Patient assessments
  • Interdisciplinary care conferences

 Agreement covers the documentation requirements for agency services furnished.

 Agreement stipulates the services that the facility must provide (such as physical space, personal care, activities of daily living assistance, medication administration, activities, housekeeping, prescribed therapies, and durable medical equipment).

 All direct care staff are aware of any requirement that they notify agency or facility of any significant changes in the patient’s condition.

 Procedures are in place and jointly agreed upon for:

  • Ordering medications that ensure the proper payer is billed
  • Reconciling billing between facility and agency
  • Contacting the facility and/or agency prior to filling a new prescription or starting new treatments
  • Ensuring that treatments, tests, or medications are ordered from the appropriate vendor and billed to appropriate payer
  • Communicating the above information to all facility staff and their responsibility on the above procedures

 Facility ensures that agency documentation is part of the facility’s current patient record and at a minimum includes:

  • State specific election, cancellation, assessment or other forms
  • Physician certifications
  • Payer verification and required forms
  • Agency interdisciplinary assessments
  • Agency plan of care coordinated with facility’s plan of care
  • Nurse’s notes and summaries
  • Physician orders and progress notes
  • Medication and treatment records

 All of the above documentation and patient records requirements are communicated to the facility records coordinator, direct care staff, and medical records consultants.

 The coordinated plan of care reflects the participation of the agency, the facility, the patient, or the patient’s representative.

 The plan of care includes directive for managing pain and other uncomfortable symptoms.

 The plan of care is revised and updated as necessary to reflect the patient’s current status.

 Staff has been made aware of patient’s right to refuse any services from the facility and the agency provider. Any refusals are documented in patient record.

 The agency provider retains overall professional management responsibility for directing the implementation of the agency’s plan of care for reason they are contracted, and any related conditions, which includes:

  • Designation of agency R.N. to coordinate implementation of care plan
  • Provision of physician, nursing, medical social work, and counseling services as appropriate
  • Provision of medications and medical supplies as needed 
  • Involvement of facility personnel in assisting with the administration of prescribed therapies in the agency plan of care only to the extent that the agency would routinely use the services of a non-agency specialist (such as patient’s family or caregiver)

 Agency provider has a written copy of all facility requirements.

By addressing issues related to the coordination of care up front, facilities can often prevent and avoid negative outcomes.  Then, if an unanticipated outcome does result in a claim, it’s much easier to determine responsibility for liability, which also tends to help co-defendants coordinate defense if the claim results in a lawsuit.