Tip of the Month
Hospice Face-to-Face Encounter: Measuring Your Compliance
The Medicare Hospice Benefit’s face-to-face encounter requirement for patients entering their third (or later) benefit period was effective in January 2011—and became enforceable on April 1, 2011. Is your hospice compliant? Hospices need to be more organized, efficient and diligent than ever in identifying (1) new admissions entering their third (or later) benefit period and (2) tracking current patients who will be recertified for a third or subsequent benefit period. Here are some quick tips to help: • Save a Copy of the CMS Common Working File (CWF) for Each Patient Make a copy of the CWF data for each new admission and transferred patient, using the “Print Screen” button on your computer keyboard—and save the copy in your records. Saving a copy of this data may help you defend or appeal a future claim if the denial is linked to an untimely face-to-face encounter. Remember, the face-to-face encounter must be completed prior to admission. • No Recertification Decision Should Be a Surprise or Emergency Track patients already on service carefully so the benefit period is known and a timely face-to-face encounter can be completed up to 30 days before the first day of the new benefit period. • Ensure that Employees Know Their Roles Make certain that your staff members understand their roles in your organization’s face-to-face encounter process—and also understand that they will be held responsible for completing their assigned tasks in a timely manner. • Audit for Compliance Make time to self assess your performance over the past 3 months: Did you check the CWF for all new admissions and transfers? Did you complete the face-to-face encounter for all new admissions entering their third or later benefit period? Did you complete the face-toface encounter for all current patients entering their third or later benefit period before the first day of their new benefit period? Consider initiating a performance improvement project if your outcomes are not satisfactory. Visit the NHPCO website for additional resources on this requirement: www.nhpco.org/facetoface.
Face-to-Face Clarifications in the Final FY2012 Wage Index!
On August 1, 2011 NHPCO issued a Regulatory Alert summarizing the Final FY2012 Wage Index rule that was released on July 29 and published in the Federal Register on August 4. The final rule includes several important clarifications concerning the face-to-face encounter. Be sure to review this Regulatory Alert—and download a copy to share with staff.
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http://www.nhpco.org/facetofacehttp://windows.microsoft.com/en-US/windows-vista/Take-a-screen-capture-print-screenhttp://www.nhpco.org/i4a/pages/index.cfm?pageID=6514http://www.nhpco.org/i4a/pages/index.cfm?pageID=6514
Table of Contents for the Digital Edition of NewsLine - September 2011