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CMS Clarification of 5-day Rule for Hospice Comprehensive Assessment

The Ohio Department of Health reached out to CMS on behalf of LeadingAge Ohio regarding the 5-day timeframe for completion of the hospice comprehensive assessment since other deemed status surveyors have not counted the time frame the same as the ODH Survey Administrator had suggested to LeadingAge Ohio staff, as noted in the LeadingAge Ohio newsletter 2 week ago.

CMS’s response to ODH regarding the 5-day completion timeframe for the comprehensive assessment is as follows:

“According to the interpretive guidelines, the comprehensive assessment needs to be completed no later than 5 calendar days after the election of hospice care. CMS interprets the date of election to be “Day 0.””

Therefore, if the patient was admitted on Wednesday and the effective date of hospice was on Wednesday, Wednesday is “Day 0”, Thursday is “Day 1”, Friday is “Day 2”, Saturday is “Day 3”, Sunday is “Day 4” and Monday is “Day 5”.

LeadingAge Ohio hopes this clears up any confusion that might have arisen previously regarding the timeframe for completion of the comprehensive assessment.  

If you have any question, please don’t hesitate to reach out to Anne Shelley at    


(Rev. 69, Issued: 12-15-10, Effective: 10-01-10, Implementation: 10-01-10)

  • 418.54(b) Standard: Timeframe for completion of the comprehensive assessment

The hospice interdisciplinary group, in consultation with the individual’s attending physician (if any), must complete the comprehensive assessment no later than 5 calendar days after the election of hospice care in accordance with §418.24.

Interpretive Guidelines §418.54(b)

All members of the IDG must be involved with completing the comprehensive assessment in order to identify the patient/family’s physical, psychosocial, emotional and spiritual needs and contribute to the development of the plan of care to address those needs. The individuals/disciplines that complete the assessment should be consistent with the hospice's own policies and procedures and the discipline's scope of practice. The RN, in consultation with the other members of the IDG, considers the information gathered from the initial assessment as they develop the plan of care and the group determines who should visit the patient/family during the first 5 days of hospice care in accordance with patient/family needs and desires and the hospice's own policies and procedures.

The patient may or may not have an attending physician. If the attending physician is unavailable or unresponsive, the hospice physician must assume this role. If the patient does have an attending physician, one or more members of the IDG should consult with this physician in completing the comprehensive assessment. This consultation can occur through phone calls or other means of communication (Fax, e-mails, text messages, etc.,) and will help to acquire a better understanding of the patient and family. Attending physicians can often provide a history of the patient’s disease process and family dynamics that can help the hospice make better care planning decisions that address all areas of need related to the terminal illness and related conditions, resulting in improved patient outcomes.

The “election of hospice care” is the effective date of the election statement. The patient may sign the hospice election statement with a later (not earlier) effective date. Hospices may choose to complete the comprehensive assessment earlier than 5 days after the effective date of the election (e.g., it may complete the comprehensive assessment at the same time the initial assessment is completed).

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