NewsLine - March 2013 - (Page 34)

Tip of the Month Revisiting the Hospice Conditions of Coverage D o you know what the hospice conditions of coverage are? It’s critical that you do. A hospice provider’s inability to evidence compliance with these conditions can be the basis for payment denial by the provider’s Medicare Administrative Contractor (MAC). In fact, this is specifically documented in Chapter 3 of the Medicare Program Integrity Manual (i.e., the IOM Manual). Let’s revisit these conditions, as outlined in the Medicare Hospice Conditions of Participation (CoPs), in §418.20. To be covered: • Hospice services must be reasonable and necessary for the palliation and management of the terminal illness as well as related conditions. • The individual must elect hospice care in accordance with §418.24. • A plan of care must be established and periodically reviewed by the attending physician, the medical director, and the hospice interdisciplinary group as set forth in §418.56. (That plan of care must be established before hospice care is provided.) • The services provided must be consistent with the plan of care. • A certification that the individual is terminally ill must be completed as set forth in §418.22. To review the above-referenced CoPs, see the PDF, Part 418—Hospice Care, from the Medicare CoPs. Another Reason to Take Note In 2006, the Office of the Inspector General (OIG) completed an analysis of hospice claims for Medicare beneficiaries residing in nursing facilities to determine compliance with these hospice conditions of coverage. The OIG’s analysis, which was published in 2009, found that: • 82 percent of the hospice claims did not meet at least one Medicare coverage requirement; • 33 percent of claims did not meet election requirements; • 63 percent of claims did not meet plan of care requirements; • 4 percent of claims did not meet certification of terminal illness requirements. What’s more, for 31 percent of the claims, hospices provided fewer services than outlined in the beneficiaries’ plans of care. A Tool to Help You These findings point to the need to be both knowledgeable Compliance Aud and compliant. To it Tool help, refer to the Compliance Audit Tool developed by the NHPCO Regulatory team. National Hospice CMS FY 2011 Top 10 Hospice Survey Deficiencies and Palliative Care Organization www.nhpco.org /regulatory This audit tool is based on CMS’s national aggregated analysis survey. Providers of hospice survey can use this tool to deficiencies identifie self assess their complian of the most frequent d during a recertific ce with each regulato ly cited. ation ry requirement. Deficienc ies are listed in order CoP L-Tag # (Regulation) (Interpretive Guidelin Compliance es) Actions required for compliance CLINICAL Yes No 1. §418.56(B) L543 All hospice care and services Standard: furnished to patients Plan of care and their families must follow an individualized written plan of care established by the hospice interdisc iplinary group in collaboration with the attending physician (if any), the patient or representative, and DOCUMENTATION the primary caregiver in accordan Yes No ce with the patient’s needs if any of them so desire. Identified for a PI project Yes Yes No No ADMINISTRATIVE Yes No Yes © National Hospice and Palliative Care No Organization, 2012 1|Page 34 NewsLine https://oig.hhs.gov/oei/reports/oei-02-06-00221.pdf http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/pim83c03.pdf http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/pim83c03.pdf http://www.nhpco.org/sites/default/files/public/regulatory/CMS_Top10HospiceSurveyDeficiencies-auditTool.pdf http://www.nhpco.org/sites/default/files/public/regulatory/CMS_Top10HospiceSurveyDeficiencies-auditTool.pdf http://www.nhpco.org/sites/default/files/public/regulatory/CMS_Top10HospiceSurveyDeficiencies-auditTool.pdf http://www.gpo.gov/fdsys/pkg/CFR-2011-title42-vol3/pdf/CFR-2011-title42-vol3-part418.pdf

Table of Contents for the Digital Edition of NewsLine - March 2013

Hospice Facts and Figures: A Six-Year Snapshot
A Message From Don
A Lesser-Known Report and How It Can Help You
Health Essentials (display ad)
Celebrating SW Month (display ad)
Serving Veterans: Does Storytelling Help or Hinder?
Related Resources on Serving Veterans
2013 NHF Gala (display ad)
Engaging and Educating a Mobile Workforce
MODEL Teams
#Speak4me Social Media Campaign
New Hospice Volunteer Ads
New National STAR Report
NHPCO’s Affinity Program (display ad)
HP Professional Scholarship Program (display ad)
Look Who’s Coming to MLC
Simione Healthcare Consultants (display ad)
Glatfelter Healthcare Practice (display ad)
Hospice Education Network (display ad)
Videos Worth Watching
Member News and Notes
Compliance Tip
NHPCO 2013 Webinars (display ad)

NewsLine - March 2013