Recent Audit Results Reveal Troubling Trend for Hospice

Among the takeaways is to be sure that all the paperwork to get them qualified for the hospice benefit is done.

Let me start today by going back to our roots, with some audit news. The home health and hospice division of National Government Services (NGS) released some interesting audit results last week. The audits were of patients who received inpatient hospice services for more than seven days.

There were a few takeaways from their results. First, I know it is obvious, but it has to be said, when you get a request for records, get the records and send them. If you billed for the service, you are responsible for sending the records, even if the care was provided in a different setting. We see this a lot with physician audits for hospital services, where they think the hospital will somehow know to send the records, but it also applies to inpatient hospice; the Medicare money is going to the hospice, not the hospital, so they must send the records.

Second, if a patient is admitted for general inpatient hospice care, but had not previously been enrolled in hospice, be sure that all the paperwork to get them qualified for the hospice benefit is done, including the statement of prognosis of less than six months. Yes, even if a patient is actively dying, and placed in hospice for acute symptom management, with a life expectancy measured in hours or days, there still needs to be a statement that their prognosis of survival is less than six months.

The majority of the denials uncovered by the audit were because NGS claims that “the beneficiary’s status did not support frequent changes in medications or care plan.” This denial reason does not seem appropriate to me. The inpatient hospice benefit specifies that the patient must be in need of pain control or symptom management that cannot be provided in any other setting, but there is no mention of how frequently there must be a change in the care. If you are part of a hospice organization, you may want to take a closer look at this, and I would certainly consider fighting those denials.

Now, I know a lot of you who read these articles probably think that David Glaser and I have some sort of “bromance” going on. We don’t. As you may have noted last week, I like earthquakes, and David is all about tornadoes. But it is true that we often think alike. And one common theme we both object to is providers setting internal rules that are not based on actual laws or regulations, depriving themselves of compliant revenue.

Recently, I read an article indicating that providers should audit their telehealth visits during COVID to ensure that the patient’s consent to a telehealth visit was documented, implying that they could be denied in an audit unless that was the case. But that’s not true. Consent is required only for a specific set of virtual visits, and not office visits performed with telehealth under the waivers. I also heard from a facility that was still requiring the admission order to be signed prior to discharge.

Now, it is perfectly OK to implement an internal policy to improve timeliness of signatures, but it is not a Centers for Medicare & Medicaid Services (CMS) condition of payment, so those claims can still be submitted for payment. Don’t help preserve the liquidity of the Trust Fund at your facility’s expense.

Programming Note: Listen to Dr. Hirsch every Monday, as he makes his Monday rounds on Monitor Mondays, 10 Eastern, and sponsored by R1 RCM