Hello everyone, welcome to our Monday Minute. Today I want to discuss with you a situation that we continue to see recur repeatedly with Hospices under medical review.
We discussed a few weeks ago the fact that medical review has ramped up significantly in Hospice especially, but Home Health as well, and there are some significant errors that we continue to see in the Hospices, that we’re involved with when it comes to medical review, that we want to make sure everyone is thinking about and paying attention to.
One of the key elements that result in denial under medical review, whether it’s from Medicare MAC, the OIG, or the UPIC auditors, etc, includes the physician certification of a Hospice patient. Whether it’s the initial certification or certification, at the point that you’re rectifying the patient, it is required that the certifying physician creates the clinical narrative to support the fact that the patient has less than six months to live assuming the disease process continues down its current course. We know that you all understand the generic statement that is typically found within that certification, but our concern lies in the physician’s actual creation of the clinical narrative, to support the fact that the patient is considered terminally ill.
We also want to emphasize the fact that they cannot just sign off on a narrative that has been created by a nurse that works for the organization. It cannot be just that the certifying physician is signing off on a narrative that was created by a nurse practitioner who may have done the face-to-face encounter. It must be a narrative created by the certifying physician him or herself.
I also want to mention the fact that if you’re in a recertification situation, you have to ensure that the face-to-face encounter has occurred, and that the clinical narrative used to support the recertification must be composed from the clinical findings that took place during that face-to-face encounter. Also, keep in mind that if the certifying physician is the physician that conducted the face-to-face encounter, there still must be two separate documents: one that is titled and signed off on as the face-to-face encounter of the patient, and a separate one that must be signed off on as the Certificate of Terminal Illness.
We have seen some pretty big horror stories of late, including the physician copying a clinical narrative from a nurse into the certification itself word for word, making no changes or edits whatsoever, and then copying that from recertification to recertification to recertification. So, the exact same wording is on everyone. These types of things are simply not going to get you through medical review.
We wanted to re-emphasize today the reality that that clinical narrative, again must be created by and signed off on by the certifying physician that is certifying that patient for Hospice services. We continue to see Targeted Probe and Educate that is being issued by all Medicare MACs, especially to newly certified Hospices. In addition, we’re seeing a ramp-up of UPIC audits, as well as SMRC audits for Hospices that are out there caring for patients.
We also want to throw in a side note here, that there is legislation that is currently being worked on – it is not officially passed yet or complete yet – but that legislation, if it does pass will include some extension of the use of Telehealth in Hospice for the face-to-face encounters. So you’ll want to keep your eyes and ears open for that legislation to be passed. It will be a five-month extension on the use of Telehealth for the face-to-face encounter if that is passed.
Thank you all for participating today. I hope you have a fabulous week. And please make sure that you are looking into all conferences that are going to be happening this spring and summer with your state and national Home Care and Hospice associations. Have a great day.