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Spiritual assessment is a document expected in more places than its contents are specified. Guidance published for the Joint Commission's hospital program says it is important to evaluate spiritual needs, beliefs, values, and preferences for two groups of patients.1 They are patients receiving psychosocial services to treat alcoholism or other substance use disorders, and patients receiving end-of-life care.1 It adds that each organization would determine how these needs will be identified, since the standards do not define such elements.1 Example questions follow, labeled as examples to consider rather than prescriptive requirements.1

Three authorities, three different variables fixed

The regulation of what a chaplain writes is divided, and each body fixes a different part of the problem. Hospice conditions of participation set the record and the schedule. Veterans Health Administration policy sets who writes and when. Navy policy sets how a note is marked, stored, and destroyed. Federal corrections regulation reverses direction, requiring the written statement from the inmate rather than the chaplain.2 A department writing its own documentation policy is reconciling instruments never drafted to sit together.

What hospice regulation fixes

A hospice interdisciplinary group must include individuals qualified in four professional roles, and the fourth is a pastoral or other counselor.3 The group reviews, revises, and documents the plan of care no less frequently than every 15 calendar days.3 The comprehensive assessment is completed no later than five calendar days after the election of hospice care.4 An initial bereavement assessment covers social, spiritual, and cultural factors affecting the ability of the family and others to cope.4

Core services carry four short subparagraphs on spiritual care. The hospice assesses the patient's and family's spiritual needs, and provides counseling to meet them in accordance with the family's acceptance of the service and in a manner consistent with their beliefs and desires.5 It makes all reasonable efforts to facilitate visits by local clergy, pastoral counselors, or other individuals who can support those needs, and it advises the patient and family that the service exists.5

What the note becomes once it is filed

A chaplain's entry in a hospice record is a clinical record entry, governed like every other one. The clinical record includes the plan of care and its updates, the assessments, clinical notes, and a good deal besides.6 All entries must be legible, clear, complete, and appropriately authenticated and dated in accordance with hospice policy and currently accepted standards of practice.6 Records are retained for six years after the death or discharge of the patient, unless state law requires longer.6 Five adjectives govern that requirement, and each describes the document rather than the encounter it records.

One data element that goes only to clergy

The federal privacy rule permits a facility directory holding a patient's name, location in the facility, condition described in general terms, and religious affiliation.7 Directory information may go to members of the clergy, and to other people who ask for the patient by name, except that religious affiliation goes to clergy alone.7 The rule ordinarily requires that the individual be given an opportunity to object. Where that opportunity cannot practicably be provided because of incapacity or an emergency treatment circumstance, the provider may still use or disclose directory information.7 An orientation handbook compressing all of that into one line will lose either the clergy exception or the emergency provision, and a volunteer at a front desk has nothing else to work from.

What Navy policy fixes instead

Chaplain notes on confidential communications are marked as Confidential or Privileged Communication and kept apart in the chaplain's personal files from professional and sensitive information.8 Protected information is secured against inadvertent disclosure, and where it is stored digitally the chaplain takes steps to ensure the privilege cannot be breached.8 Chaplains ensure destruction through a secure means when the records are no longer needed, and religious program specialists and chaplain assistants will not keep notes on any confidential communications.8

Those provisions govern marking, storage, and disposal rather than substance. The instruction reaches content once, requiring that identities be thoroughly protected when current or former counselees are referenced in consultation, supervision, or education.8

What Veterans Health Administration policy fixes

Where a more in-depth spiritual assessment is indicated, a chaplain is the only subject matter expert authorized to conduct it and to devise a spiritual care plan.9 Documentation of spiritual assessments is required within stated periods that vary by setting. It is within the first 24 hours in intensive care and hospice, and within 72 hours in acute inpatient mental health.9 It is within seven days in residential substance abuse treatment, and within 14 days in Community Living Centers, spinal cord injury, and polytrauma.9 Four deadlines govern a document whose contents that directive does not prescribe.

The record we never see, and the forms we do

A patient's clinical record is not a document to send to an outside editor, and we do not ask for one. We make no theological, pastoral, or clinical judgment. What reaches us is the other kind of document: policies, assessment forms, orientation handbooks, competency descriptions, and published reflection. We check that a term defined in a policy is used that way in the training built from it. We check that a period stated in one paragraph is the period stated in another, and that a form's questions can be answered by the person who will be holding it. Client material is treated as confidential without exception.

A department writing its own assessment form does what the authorities above it declined to do. The form is used by people who never read the regulations behind it, and its questions are the only part of that structure most of them will see.

References

  1. The Joint Commission, Standards FAQ, "Spiritual Beliefs and Preferences: Evaluating a Patient's Spiritual Needs," Hospital and Hospital Clinics program, Provision of Care, Treatment, and Services, first published April 11, 2016, last reviewed July 19, 2022. https://www.jointcommission.org/standards/standard-faqs/hospital-and-hospital-clinics/provision-of-care-treatment-and-services-pc/000001669/
  2. National Archives and Records Administration, Code of Federal Regulations, 28 CFR 548.20, "Dietary practices." https://www.ecfr.gov/current/title-28/section-548.20
  3. National Archives and Records Administration, Code of Federal Regulations, 42 CFR 418.56, "Condition of participation: Interdisciplinary group, care planning, and coordination of services." https://www.ecfr.gov/current/title-42/section-418.56
  4. National Archives and Records Administration, Code of Federal Regulations, 42 CFR 418.54, "Condition of participation: Initial and comprehensive assessment of the patient." https://www.ecfr.gov/current/title-42/section-418.54
  5. National Archives and Records Administration, Code of Federal Regulations, 42 CFR 418.64(d)(3), "Condition of participation: Core services." https://www.ecfr.gov/current/title-42/section-418.64
  6. National Archives and Records Administration, Code of Federal Regulations, 42 CFR 418.104, "Condition of participation: Clinical records." https://www.ecfr.gov/current/title-42/section-418.104
  7. National Archives and Records Administration, Code of Federal Regulations, 45 CFR 164.510, "Uses and disclosures requiring an opportunity for the individual to agree or to object." https://www.ecfr.gov/current/title-45/section-164.510
  8. Secretary of the Navy Instruction 1730.11, "Confidential Communications to Chaplains," 31 October 2022, copy hosted by the United States Coast Guard. https://www.uscg.mil/Portals/0/1730_11.pdf
  9. Veterans Health Administration, VHA Directive 1111, "Spiritual Care," Department of Veterans Affairs, July 21, 2021, scheduled for recertification on or before July 31, 2026. https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=9350

A worked example: Spiritual Care Documentation Policy

Hospice policy excerpt

Accreditation guidance asks that spiritual needs be evaluated and states that the standards do not define the elements, which leaves the department to write its own instrument. The regulations that do supply periods and standards sit in several places. A policy that gathers them loosely produces staff who know a duty exists and not when it falls due, and a front desk working from the wrong version of a privacy rule.

Before

Chaplains will complete a spiritual assessment for all patients in a timely manner and document it in the record. The chaplain will keep notes confidential. Volunteers answering the front desk may give out a patient's name, room number and religious affiliation to anyone who asks for the patient by name.

After

Spiritual assessment. A chaplain completes and documents the comprehensive assessment for each patient no later than five calendar days after the election of hospice care. The interdisciplinary group reviews, revises and documents the plan of care as frequently as the patient's condition requires, and no less frequently than every 15 calendar days.

Record entries. Entries in the clinical record are legible, clear, complete, and appropriately authenticated and dated, in accordance with this policy and currently accepted standards of practice.

Facility directory. Where a caller or visitor asks for a patient by name, staff may give the patient's name, location in the facility and condition described in general terms. Religious affiliation is released to members of the clergy and to no one else. Directory information is released only where the patient has been given an opportunity to object and has not objected. Where that opportunity cannot practicably be provided because of incapacity or an emergency treatment circumstance, directory information may still be used or disclosed.

What changed, and why

WasNowReason
in a timely mannerno later than five calendar days after the election of hospice careA phrase no reader can act on is replaced by the period the regulation states. Two staff reading the original will pick two different deadlines and both will believe they complied.
document it in the recordEntries in the clinical record are legible, clear, complete, and appropriately authenticated and datedThe policy names the standard an entry is measured against rather than only naming the act of writing one.
religious affiliation to anyone who asks for the patient by nameReligious affiliation is released to members of the clergy and to no one elseThe released item is separated from the audience permitted to receive it. In the original the two are joined, and the sentence states the opposite of the rule.
room numberlocation in the facilityThe wording of the rule is used, which matters where a patient has moved and the room number on file is stale.
Volunteers answering the front desk may give outWhere a caller or visitor asks for a patient by name, staff may giveThe permission is tied to the question being asked rather than to the role of the person answering, and it reaches every member of staff who picks up a telephone.

Final specimen (PDF, 4 KB) Marked-up specimen (PDF, 5 KB)

Specimen prepared by EditFast for illustration only. Not a real document, record or filing. Any resemblance to an actual organization, person or record is unintended. Not legal, regulatory, clinical or professional advice.

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