An increase in denials is occurring due to two very important hospice medical review topics – the Face-to-Face Encounter and the Certificate of Terminal Illness.
Face-to-Face Encounter
The Face-to-Face Encounter is mandatory for every 3rd or subsequent benefit period in hospice. This encounter must be conducted by either the medical director/physician member of IDG or a nurse practitioner employed by the hospice. Nurse practitioners cannot be a contractor. If a nurse practitioner carries out the Face-to-Face Encounter, they are required to sign an attestation confirming that they have communicated the clinical findings to the certifying practitioner. These findings are then used to formulate the clinical narrative for the Certificate of Terminal Illness (CTI).
Certificate of Terminal Illness
For each certification period in hospice, issuing a Certificate of Terminal Illness is mandatory. Starting from the 3rd benefit period onward, this certificate must incorporate the clinical findings from the Face-to-Face Encounter. Whether a medical director, a physician member of the IDG, or a nurse practitioner conducts it, the clinical data must be used to craft the clinical narrative of the CTI. Hence, the Certificate of Terminal Illness should not be prepared or signed prior to the Face-to-Face Encounter occurring in the third or subsequent benefit periods.
It is critical to ensure that the attestation statements, positioned directly above the practitioner’s signature on the Face-to-Face Encounter documentation or the patient’s certification on the CTI, see the Medicare Benefit Policy Manual Chapter 9, Section 20.1.
Moreover, if the certifying physician is also the one performing the Face-to-Face Encounter, it is essential to maintain two distinct documents: one detailing the Face-to-Face Encounter, and the other, the Certificate of Terminal Illness, each documented, signed, and dated independently. These documents must not be merged into a single clinical record.
These two reasons are the primary causes of denial during hospice medical review, alongside the substantiation of the terminal illness. They form the cornerstone of the certification process for each hospice certification period. Understanding and adhering to the detailed requirements for both the Face-to-Face Encounter and the CTI is vital for clinicians.
Should you need assistance regarding hospice medical review, or have questions related to hospice documentation, please feel free to reach out to us.
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