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Tuesday, May 26, 2015

Joint Commission makes some changes to Hospice standards that are now in alignment to the federal government medicare regulations.

The Joint Commission has revised a number of hospice requirements to demonstrate Joint Commission equivalency with Medicare Conditions of Participation (CoPs). Effective July 1, 2015, the revisions affect a number of chapters in Joint Commission accreditation manuals. For facility-based (inpatient) hospices, significant changes have been made to the occupancy requirements. Life Safety standards for Rooming and Lodging (LS.04.01.20, LS.04.01.30, and LS.04.01.50) are removed, and Health Care occupancy standards LS.01.01.01-LS.02.01.70 will be effective. Previously, The Joint Commission required facility-based hospice providers with 11 or fewer patients to meet the Rooming and Lodging requirements in chapter 26 of the National Fire Protection Association (NFPA) Life Safety Code® (NFPA 101-2000). However, the Centers for Medicare & Medicaid Services (CMS) requires all facility-based hospice providers to comply with the requirements for Health Care Occupancies in chapters 18 and 19 of the NFPA Life Safety Code, 2000 edition. Therefore, these changes are applicable to all Joint Commission accredited facility-based hospice providers – both deemed and non-deemed organizations.
Some significant differences between Rooming and Lodging occupancy requirements and Health Care occupancy requirements include:
  • Separation between different occupancies, such as Health Care or Business occupancies, must be at least two-hour fire resistant rating barriers. Also, Health Care occupancies require smoke compartments. Hazardous areas, such as soiled utility rooms, must also be separate from patient care areas.
  • Means of egress (exit access, exits and exit discharge) are clear and unobstructed; Health Care occupancies require that the 8-foot patient care corridor be kept clear of storage; and door configurations must operate as designed.
  • The fire alarm system must activate automatically based on NFPA 72-1999. 

Friday, May 8, 2015

Hospice Specifics for Recertification of the expected

Hospice Certification / Recertification Requirements

Medicare Benefit Policy Manual (CMS Pub. 100-02), Ch. 9 §20.1

In order for a patient to be eligible for the Medicare hospice benefit, the patient must be certified as being terminally ill. An individual is considered to be terminally ill if the medical prognosis is that the individual’s life expectancy is 6 months or less if the illness runs its normal course. The certification/recertification is a critical piece of documentation necessary to ensure Medicare payment for the hospice services you provide.

The hospice must obtain verbal or written certification of the terminal illness, no later than 2 calendar days (by the end of the third day) after the start of each benefit period (initial and subsequent). Initial certifications may be completed up to 15 days before hospice care is elected. Recertifications may be completed up to 15 days before the start of the next benefit period.

If written certification/recertification cannot be obtained within 2 calendar days, verbal certification must be obtained. The hospice must determine who may accept verbal certification from a physician in compliance with state and local law regulations.

In addition, the hospice must ensure the written certification/recertification is signed and dated prior to billing Medicare, or their claim(s) may be denied.
Content of the Certification/Recertification

The certification should be based on the clinical judgment of the hospice medical director (or physician member of the interdisciplinary group (IDG)), and the patient’s attending physician, if he/she has one.

In addition to the initial certification for hospice, the patient must be recertified for each subsequent hospice benefit period.

The written certification/recertification must include:

    The statement that the patient’s medical prognosis is that their life expectancy is 6 months or less if the terminal illness runs its normal course
    A brief narrative, written by the certifying physician, explaining the clinical findings that support the patient’s life expectancy of six months or less. This narrative can be a part of the certification/recertification form or as an addendum to the form.
        If the narrative is part of the form, it must be located immediately above the physician’s signature.
        If the narrative is an addendum, the physician must also sign the addendum immediately following the narrative.
        Do not include check boxes or standard language used for all patients. The narrative cannot be completed by other hospice personnel; it must be completed by the certifying physician.
        The narrative shall include a statement, located above the physician signature and date, that attests to the fact that by signing the form, the physician confirms that he/she composed the narrative based on his/her review of the patient’s medical record or his/her examination of the patient.
    The benefit period dates that the certification or recertification covers.
    Effective for recertifications on/after January 1, 2011, narratives associated with the third benefit period and subsequent benefit periods must explain why the clinical findings of the face-to-face encounter support a life expectancy of six months or less. Documentation must include the date of the encounter, an attestation by the physician or nurse practitioner that he/she had an encounter with the beneficiary. If the encounter was done by a nurse practitioner, he/she must attest that clinical findings were provided to the certifying physician.

Signature Requirements for Certification

Acceptable signatures:
    Handwritten signatures
    Electronic signatures
    Facsimile of original written or electronic signatures

Unacceptable signatures-STAMPS
    Stamped signatures—NOT ACCEPTABLE

Signatures for Initial Certifications:

For the first benefit period after election of the Medicare hospice benefit, the certification must be signed and dated by the:

    Medical director of the hospice or the physician member of the hospice interdisciplinary group (IDG); and
    The beneficiary’s attending physician (if they have one).

Note: To sign the certification, the attending physician must be a doctor of medicine or osteopathy, and be identified by the beneficiary at the time he/she elects to receive hospice care as having the most significant role in the determination and delivery of the individual’s medical care.

Signatures for Recertifications:

For the recertification (for subsequent hospice benefit periods), only the hospice medical director or the physician member of the IDG is required to sign and date the certification. The beneficiary’s attending physician is not required to sign and date the recertification.
Face-to-Face (FTF) Encounter

For recertifications on/after January 1, 2011, a hospice physician or hospice nurse practitioner must have a face-to-face encounter with each hospice patient prior to the beginning of the patient’s third benefit period, and prior to each subsequent benefit period. The FTF must occur within 30 calendar days prior to the start of the 3 rd or later benefit period, unless exceptional circumstances are met. Examples of exceptional circumstances include an EMERGENCY WEEKEND PROTOCOL.

Common Hospice Certification Errors

Medicare cannot make appropriate payment without correct dates, signatures and identifying roles of the physician(s). The following list identifies the common types of missing and inadequate information:

    Predating physician(s) certification signatures
    Not having both the hospice medical director and attending physician (if applicable) sign the initial certification as required
    The physician narrative is missing
    The attestation statement is missing
    Not having verbal certifications by both the medical director and attending physician (if applicable)
    No physician(s) signatures
    Illegible physician signatures
    Physician did not date his/her signature

    Not clearly stating the dates the certification period encompasses