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& Palliative Care represents the majority of Virginia's hospices and we recommend that the following section be repealed:  12VAC5-391-330B --  ‘The medical director shall have admitting privileges at one or more hospitals and nursing facilities that provide inpatient service to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