Avoid Citations by Reviewing CMS’ Guidance on Hospice Election Statements

Posted on Thursday, December 8, 2016 10:37 PM

Agencies must closely examine CMS’ guidance explaining what complete, written certifications from physicians must include. Another recommendation is to review your hospice’s election statement to ensure it includes the information CMS provided within the new sample statement.

This important step could protect your agency from CMS survey citations and claims denials, industry experts contend.

The new guidance released November 22 is included within MLN Matters articles SE1628 and SE1631.

The articles follow an OIG report from September 15 that determined many election statements lack proper language and many certification statements fail to meet
requirements (HHL 9/26/16).

The new articles provide direct guidance from CMS and thus will be “tremendously valuable” for hospices, says Theresa Forster, Vice President for Hospice Policy & Programs for the National Association for Home Care & Hospice.

SE1631 provides hospices a sample election statement. For example, the sample doesn’t specifically mention care hospices provide is “palliative.”

Instead, the sample statement includes a portion that explains, “Hospice care is to relieve pain and other symptoms related to my terminal illness and related conditions and such care will not be directed toward cure. The focus of hospice care is to provide comfort and support to both me and my family/caregivers.”

The National Hospice and Palliative Care Organization (NHPCO) was pleased “palliative” wasn’t included in the sample form, but it wants CMS to communicate to contractors that they shouldn’t deny claims that don’t say “palliative” in election statements.

NHPCO also is concerned that the sample form includes space for a witness signature, says Judi Lund Person, Vice President, Regulatory and Compliance for
the organization.

SE1628 provides guidance on requirements for a valid physician certification and recertification, including examples of physician narratives that meet those requirements.

“It actually includes some examples and that’s something that wasn’t in the manual previously,” Forster says.

One such narrative: “78-year-old male with a diagnosis of Stage 4 lung cancer. Completed three rounds of chemotherapy, but cancer has metastasized to the liver and bone. Patient no longer wants to continue chemotherapy and states he wants comfort measures only. Increased dyspnea and pain over past two weeks. Is now oxygen dependent with 2LNC and requires morphine every six hours for bone pain and shortness of breath.”

Among other things, Person says, hospices should ensure signatures and dates are in the proper place.

CMS recommends certifications include the following information:
• A statement about the patient’s life expectancy
• Patient-specific clinical findings supporting a life expectancy of six months or less
• Proper signatures and dates.
• A brief narrative from the physician stating clinical findings supporting a life expectancy of six months or less
• Face-to-face encounter documentation

For the full article, please see the December 12, 2016 Home Health Line Edition.

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