15.3 National Hospice and Palliative Care Standards

Standards versus CoPs: the distinction CHPN is fishing for

A CoP is a federal regulation. If the hospice does not meet it, CMS can terminate Medicare participation, impose condition-level deficiencies, and deny payment. A standard is a professional or accreditor expectation. It may be stricter, more detailed, or more educational than the CoP. It is not a substitute for 42 CFR Part 418.

CHPN stems often pair four documents in one vignette: a CoP clock, an NHPCO quality component, an HPNA nursing standard, and an accreditation finding. The correct answer usually names the source that actually binds the decision. Payment eligibility and survey deficiency → CoPs. Nursing role, ethics, and competency → HPNA. Program-wide quality design and QAPI culture → NHPCO. Optional external survey that can stand in for a routine certification survey → TJC / CHAP / ACHC, with CMS still in the background.

NHPCO Standards of Practice for Hospice Programs

The National Hospice and Palliative Care Organization (NHPCO) has published Standards of Practice for Hospice Programs for decades (the 2018 edition is the widely cited program-level set). NHPCO’s national-association branding has continued to evolve; CHPN still tests the standards framework, not the letterhead. The standards are organized around ten components that give a hospice a 360-degree look at clinical and non-clinical operations and that explicitly support the CoP requirement for Quality Assessment and Performance Improvement (QAPI) (§ 418.58):

NHPCO standards help a hospice meet and exceed CoPs. They do not authorize a hospice to skip a 48-hour RN assessment, an IDG, or a medical-director certification because “we follow NHPCO.” On a CHPN item, “the NHPCO standard is nicer” loses to “the CoP was missed.”

HPNA professional practice

The Hospice and Palliative Nurses Association (HPNA) publishes Palliative Nursing: Scope and Standards of Practice (6th edition, 2021, Dahlin). HPNA’s document sits beside the American Nurses Association (ANA) Nursing: Scope and Standards of Practice. Together they answer: what is the registered nurse accountable for in hospice and palliative care?

HPNA standards cover assessment, diagnosis, outcomes, planning, implementation, evaluation, ethics, culturally congruent practice, communication, collaboration, leadership, education, evidence-based practice, quality of practice, professional practice evaluation, resource utilization, and environmental health — the professional-practice skeleton CHPN Domain 5 expects you to apply, not memorize as a numbered list. HPNA also issues position statements (for example, on ensuring high-quality hospice and palliative care) that point nurses to CoPs, NCP guidelines, and interdisciplinary accountability.

The CHPN credential is HPCC’s exam; HPNA is the specialty association. HPCC tests whether the nurse practices to HPNA professional standards inside a CoP-compliant program. A nurse who “follows my heart” while skipping IDG coordination is not meeting HPNA standards or CoPs.

Practical HPNA implications on CHPN items:

• The RN coordinates the plan of care and does not treat the IDG as optional group therapy
• Delegation to aides and LPNs stays inside scope and hospice policy
• Quality improvement is a nursing obligation, not only a QAPI coordinator’s hobby
• Advocacy includes explaining election waivers, relatedness, and BFCC-QIO rights without coercing election

Joint Commission, CHAP, and ACHC: optional deemed-status pathways

Medicare certification can be obtained through a state survey agency survey against the CoPs. It can also be obtained through a deemed-status survey by a CMS-approved accrediting organization. For hospice, the three names CHPN expects are:

• The Joint Commission (TJC) Home Care Accreditation, hospice deemed-status option
• Community Health Accreditation Partner (CHAP)
• Accreditation Commission for Health Care (ACHC)

Deemed status means CMS has authorized that accreditor to survey the hospice against standards that CMS has determined are at least equivalent to the CoPs. A successful deemed-status survey leads to accreditation and a recommendation for Medicare certification. CMS, not the accreditor, grants Medicare certification.

Accreditation is optional as a pathway. A hospice is not required to buy TJC, CHAP, or ACHC in order to exist. Many hospices choose accreditation because referral partners, managed-care contracts, or leadership want the external seal — and because a deemed survey can replace the routine recertification survey.

Medicare surveys still exist

This is the sentence CHPN will disguise in a long stem:

Deemed status does not retire Medicare. CMS and state survey agencies retain authority to conduct validation surveys, complaint investigations, and other federal or state surveys in all certified hospices, accredited or not. Accreditors’ deemed surveys for Medicare participation are typically unannounced. An accredited hospice can still receive CoP citations, payment denials, and, in extreme cases, termination.

If a CHPN option says “after Joint Commission accreditation, CMS never surveys hospice again,” it is wrong. If an option says “only The Joint Commission has deeming authority,” it is wrong — CHAP and ACHC also hold hospice deeming authority. If an option says “accreditation exempts the hospice from HQRP,” it is wrong. Quality reporting is a CMS program, not an accreditor courtesy.

Who writes what

CHPN scenario: the “we’re accredited” defense

Surveyors arrive on a complaint about missed weekend nursing visits. Leadership says the hospice is ACHC-accredited and follows NHPCO workforce standards, so the complaint should be closed. The CHPN analysis: accreditation does not block a complaint survey; § 418.64 still requires the hospice to meet nursing needs identified in the assessment; NHPCO workforce excellence may explain how the agency should staff, but it does not erase a CoP miss. Document the missed visits, restore coverage, and treat QAPI as the place to fix the system — not as a shield against CMS.