NewsLine - May 2011 - (Page 32)

Short Takes CMS Clarifies Aspects of the Hospice ‘Face-to-Face’ Encounter NHPCO members continue to raise questions about implementation of the Hospice Face-to-Face Encounter. In the March 28, 2011 edition of Regulatory Roundup, NHPCO shared the following clarifications from the Centers for Medicare and Medicaid Services (CMS) concerning several aspects of the rule. Using the ‘Same Physician’ for Recertification: One physician may be employed or contracted to conduct faceto-face encounters and sign the face-to-face attestation, while a different physician (either an employee of the hospice or under contract to the hospice) may complete the recertification process. If different physicians are involved, the physician conducting the face-to-face encounter and attestation should communicate the clinical findings to the physician who will be completing the recertification. For details, see CR7337. Discharges When Face-to-Face Encounter is Not Completed on Time: If a hospice does not meet the face-to-face encounter time frames (even for reasons due to exceptional circumstances), the hospice has failed to meet the threshold requirements for recertifying the patient’s terminal illness. Therefore, the patient is no longer deemed eligible for the Medicare Hospice Benefit (MHB). The hospice may continue to serve the patient under hospice care, but must assume all financial responsibility for the care until the face-toface encounter is completed. If the face-to-face encounter is completed and if the patient continues to meet the MHB’s eligibility requirements, the patient can be re-admitted to the MHB. For details, see the CMS FAQ. Physician Signatures for New Admissions in Second or Later Benefit Periods: Should both the attending and the hospice physician sign the recertification form when the patient is new to the hospice, but has received hospice services previously? Medicare Hospice Regulations [418.22(c)(1)] require both the attending physician and the hospice physician to sign the certification of terminal illness forms only for the initial certification. Therefore, if the patient is in the second or later benefit period, only the signature of the hospice physician is required. Using Billing Occurrence Code 77: Per CMS, occurrence code 77 may not be used when the face-to-face encounter is not complete. The law requires the encounter to be completed prior to the start of the benefit period for eligibility to continue. 32 NewsLine http://www.cms.gov/transmittals/downloads/R141BP.pdf http://www.nhpco.org/i4a/pages/Index.cfm?pageID=6468 http://www.cms.gov/Hospice/downloads/Hospice_Face2Face_FAQ_032511.pdf http://www.cms.gov/Hospice/downloads/Hospice_Face2Face_FAQ_032511.pdf http://www.cms.gov/Hospice/downloads/Hospice_Face2Face_FAQ_032511.pdf

Table of Contents for the Digital Edition of NewsLine - May 2011

POLST: An Evidence-based Tool for Advance Care Planning
A Message From Don
ICD-10: It’s Time to Begin Preparing
26th MLC Supporters (display ad)
Experience the ACHC Difference (display ad)
LifeBeat at Southern Tier Hospice and Palliative Care
Introducing NHPCO’s Custom Print Marketplace (display ad)
Voice of NCHPP: Spiritual Care: A Physician’s Perspective
NCHPP: Getting Involved
Recruiting Problems? HMR (display ad)
New - Hospice MDP Summer School (display ad)
CMS Clarifies Aspects of the Face-to-Face Encounter
Harvest: A New Film That Will Resonate With Members
Member News and Notes
Upcoming Educational Offerings
Cover 2

NewsLine - May 2011