Hospice Updates


I had the privilege of attending an educational session with Jamie Boudreaux with the Louisiana-Mississippi Hospice and Palliative Care Organization this week.  I highly recommend taking advantage of any opportunity that comes your way to attend any LMHPCO events.

During Jamie’s talk, he referenced numerous changes that were proposed for 2016 in Hospice.  After hearing so much about this exciting document, I couldn’t wait to read it.  You should read it, too and send your comments should you have any.

The highlights – or at least those points that we find interesting as coders and clinicians, are found below.  This is not an all inclusive account of the regulations and I strongly encourage you to read them for yourself.

Good News First

You are getting a raise.  It is projected that hospice payments will rise almost 2 percent.  But that’s not all.  Remember that talk about a U Shaped curve?  It isn’t exactly a ‘U’ but you now have a change in how you will be paid.

There are two factors that will increase your payment.  In the current system, due to the increased expenses in admitting a patient and establishing a care plan, a patient will be on service for approximately 21 days until the hospice breaks even.  As time goes by, the payment stays the same and hospice providers are collecting the same payment for long stretches of time when the patient has minimal needs.  This is traditionally when the hospice made money.  As death approaches, the costs usually increase again.

As such, two new provisions have been added.

During the first 60 days of hospice, payment will be at a rate (adjusted for your area) of $187.63

After day 60, per diem payment will fall to $145.21

Important:  An episode of hospice care is considered to be all episodes that are separated by no more than 60 days.  You cannot discharge and readmit a patient prior to 60 days and expect the higher rate.  Hospice providers who pick up patients from other hospices as in a transfer will be similarly unable to claim the higher rate.

But there’s more!

During the last seven days of care, hospices will be able to bill a Severity Intensity Add-on or SIA.  In addition to the hospice per diem rate, for Registered Nurse and Social Work visits during those last 7 days, an additional rate equivalent to the continuous care rate may be billed up to 4 hours.  That means that in addition to the daily rate, a hospice can receive almost $160.00 more.

There are conditions:

  • The additional rate is only available for Registered Nurse and Social Work visits.
  • The SIO is not available for patients in nursing homes.
  • The beneficiary is discharged due to death
  • The care occurs in the last seven days of life.

The reported reason for this change is to encourage providers to provide additional care when it is needed the most.  A full 20 percent of patients did not receive a visit on the day of death.

So that’s the good news.  Hospice providers will be receiving additional cash when expenses are the highest. Back to the beginning of the document where the news isn’t quite so exciting.

Background

Normally, we would not bore you with the background of any proposed regulations but in this case, the continual references to the 1983 hospice benefit rules probably indicate that some of the recent changes and proposed changes are an indication that hospices haven’t gotten it right, yet.

The tone of this document is well worth your time to read so you can heed the inherent warnings.

Attending Physician

The rule is one per patient.  The fact that over one third of patients have multiple physicians submitting claims indicating they are the attending physician results in Medicare paying the physicians when in fact, the hospice is the correct payor source.  Don’t get caught doing this.

A signed document is required when a patient chooses to change physicians.

The Joy of Scrutiny

Medicare is not mandating surveys to be conducted at least every three years as opposed to the every 6 year rule now.  Select hospices who have long lengths of stay can expect to find themselves on a private list where all claims for services past 180 days of admission are routinely reviewed.  Do not get on this naughty list.

Remember, the data exists for Medicare to look at the average length of stay in addition to the percentage of patients on service greater than 180 days.  That’s a really good number to keep handy, by the way.  You can have a lot of patients on service for a year or more offset by some short lived admissions so your average length of stay may be okay but you might still have far too many patients on service longer than would be considered reasonable and necessary.

Utilization

Obviously this is not a regulation but it is an indication of the overall ‘tone’ being set by document.

The number of Medicare beneficiaries receiving hospice services has grown from 513,000 in FY 2000 to over 1.3 million in FY 2013. Similarly, Medicare hospice expenditures have risen from $2.8 billion in FY 2000 to an estimated $15.3 billion in FY 2013

…..this increased spending is partly due to an increased average lifetime length of stay for beneficiaries, from 54 days in 2000 to 98.5 days in FY 2013, an increase of 82 percent.

Cost Savings?

image

This chart shows how many dollars per day were spent on patients in the 180 days prior to hospice admission and how many days spent in the care of a hospice.  As it turns out, both of these numbers are critical for determining potential savings to the Medicare trusts.

On the vertical column, you can see the grand total of days a patient spent in hospice.  The horizontal line shows what the average daily cost of the patient was prior to admission.

This is Medicare’s work.  We do not agree with this method of cost analysis.  However, any differences of opinions regarding the formulas used do not account for $158,000 per patient with a diagnosis of Alzheimer’s Dementia which is about what it works out to be over 120 days.

The Medicare Hospice Benefit is not reducing healthcare costs in terminally ill patients. This is a problem folks.

Live Discharges

The proposed regulations are very clear that nobody expects the live discharge rate to be zero.  Patients have the right at any time to revoke their election at any time.  Some patients start to get better especially after they have been taken off 25 medications designed to prolong their life.  They move and sometimes they just hate your hospice and revoke.

Based on the data within the proposed regulations, there can be no doubt that an above average live discharge rate strongly correlates with other undesirable characteristics of hospice provider.  The patients discharged alive are from providers that also have more long term, low maintenance patients.  Additionally, patients in these hospices cost Medicare more in terms of money spent for nonhospice care.

The proposed regulations reiterated the limited number of reasons that a provider can discharge a patient.  They are as follows:

    • death
    • revocation
    • transfer to another hospice
    • moving out of the hospice’s service area
    • discharge for cause,
    • patient no longer being considered terminally ill (that is, no longer qualifying for hospice services

When discharging for cause, ensure that all reasons are documented especially if a patient has been on service for a while.  When more than one neighborhood becomes unsafe on day 181 of a hospice episode of care, it makes for a pattern.

There are very few legitimate causes for discharge in hospice. and the regulations are clear that discharging patients due to cost is not approved by Medicare.

Comments from Providers

The data in the proposed regulations is stunning but the real damage comes from various and sundry anecdotes.  It is important for providers to understand what those who right the rules are thinking and how they are thinking.   Copied directly from the regs:

We have received anecdotal reports from non-hospice providers who have rendered care and services to hospice beneficiaries in which the non-hospice provider states that the care given was related to the terminal prognosis of the individual. These reports go on to say that they have contacted hospices to coordinate the care of the hospice beneficiary only to be told by those hospices that they disagreed with the non-hospice providers’ clinical judgment that the care was related to the terminal prognosis.

We have been told that hospices are refusing to reimburse the non-hospice provider for care related to the terminal prognosis.

non-hospice providers also informed us that the hospices told them to code the claim with a different diagnosis or to code condition code 07 (treatment of Non-terminal Condition for Hospice) or the modifier “GW” (service not related to the hospice patient’s terminal condition) on their claims to ensure that the non-hospice provider would consequently get paid through Medicare.

We have also received anecdotal reports from hospice beneficiaries and their families that they have been told by the hospice to revoke their hospice election to receive high-cost services that should be covered by the hospice, such as palliative chemotherapy and radiation.

In addition to publishing these comments, staff memos to employees of specific large hospices were included stating that their providers should go after the long term patients.

Terminal Prognosis

This is the last time that you should ever consider the words ‘terminal’ and ‘diagnosis’ together.  People do not have terminal conditions in isolation.  They have terminal prognoses.

All of the research and numbers that Medicare has presented all go to support their belief that hospices are not living up to their provider agreement which includes care for the diagnoses that is most likely to cause death and any and all other diagnoses that affect the patient’s comfort, are a result of the terminal prognosis or contribute to the severity of the prognosis.

Consider a patient who needs bypass surgery but because of diabetes, long term use of steroids for arthritis and a longstanding history of noncompliance due to a psychiatric illness, she is not a surgical candidate.  There is no one diagnosis that is terminal.  All of them play a role in his terminal prognosis and all must be addressed by the hospice.

Coding

You are making progress!  In the 2015 regulations it was noted that 72 percent of hospice claims had only a single diagnosis.  This year, for the 2016 update, the percentage of claims with only diagnosis is down to 49 percent.

In addition, because there has been confusion and discussion about the nature of the ‘terminal prognosis’, providers have been omitting diagnoses that are significant to the patient’s overall condition.

Since the inception of hospice, adherence to the International Classification of Diseases (ICD) has been mandated.  This means that the primary diagnosis and all diagnoses that affect the patient’s ability to respond to or participate in the plan of care are to be included.

Therefore, we are clarifying that hospices will report all diagnoses identified in the initial and comprehensive assessments on hospice claims, whether related or unrelated to the terminal prognosis of the individual. This is in keeping with the requirements of determining whether an individual is terminally ill. This would also include the reporting of any mental health disorders and conditions that would affect the plan of care as hospices are to assess and provide care for identified psychosocial and emotional needs, as well as, for the physical and spiritual needs.

I have heard of denials because patients were admitted to psychiatric facilities that billed Medicare because the patient’s ‘terminal diagnosis’ was not psychiatric in nature.  I suspect this has happened numerous times because psychiatric conditions are mentioned more than once in this document.

We will monitor compliance with required coding practices and collaborate with all relevant CMS components to determine whether further policy changes are needed or if additional program integrity oversight actions need to be implemented.

Let the last sentence of the section on coding resonate loudly on your priority list.  We can and will code for you.  You can learn ICD-10 coding or you can outsource to another company.  Alternatively, we can help with appeals, Focused Medical Review, or ZPIC audits.  The choice is yours but if you’ve ever been through that kind of regulatory scrutiny before, you would not choose non-compliance.

There is more – so much more but try digesting this first and we’ll keep an eye on the final release and do our best to summarize it for you.

More than Half!


More than half of the dollar amount of claims reviewed by one intermediary were denied in the last quarter of 2014. Multiple results were published this past week. Most were for smaller amounts but the denial rates were similar. The results posted below are the results for an edit of claims with a HIPPS code of 1BGP*. These are patients who were in an early episode, a clinical severity of 2 and a functional level of two, and a service level of 5. This represents a very high paying patient who is receiving therapy but otherwise isn’t all that sick.

Over half of the dollars that were billed for these claims were taken back or not paid because of a focused medical review.

For now, this is where we stand. As unfair as it may seem, there is no other option than to address these numbers until your claims make their way through the appeals process. Please do not think you are being told to grin and bear it because we are angry, too.

Region Midwest Southeast
Total dollars reviewed 6,074,393.71 5,588,813.76
Total Dollars denied 3,498,994.66 3,285,618.64
Denial Rate 57.6 58.8

The good news is that most of the claims were denied for Face-to-Face encounter documentation and we can obviously expect fewer denials in the future but not for several months. The claims that will be scrutinized for the next several months will all have required Face-to-Face documentation.

The bad news is that many of these claims were denied for multiple reasons. For instance, in the Southeast Region, there were a total of 1817 claims reviewed producing 1562 denials. There were 865 claims that were denied because ‘MR HIPPS Code Change  – Documentation Contradicts OASIS MO Item(s)’ Look for this denial related to diagnosis coding and therapy. The functional and clinical domain (except for diagnosis) can change but the diagnosis coding should be fairly static throughout an episode unless there has been change.

What can you do?

Agencies need to fight fire with fire. If it’s details they want, give them every detail you have. Deprive them of the opportunity to take your money back.

  1. Admit all patients with a goal of one episode at most. Any further episode must be approved by someone who has reviewed the chart.
  2. Involve the entire staff in educating each other about documentation.
  3. Constantly remind nurses who already document well that the increased focus is not about them but getting paid.
  4. Documentation takes time and should be included as part of the visit rate. If nurses are running the roads all day and producing sloppy documentation at night when they are tired, visits need to be backed down until all work can get done.

The best solutions will come from within your agency. Take advantage of each individuals talents and get everyone involved. Post excellent notes where everyone can see them.

If you think you cannot afford this level of attention to detail, you might rethink that position if you are hit with an edit.

We can help prevent that with our fabulous coders who will ensure proper coding so the careplan can be written within a couple of days and followed to a T.   Call us or connect by email.

 

 

Nina Pham


 

The CDC, among others, have suggested that perhaps more training is needed to ensure that direct health care workers are properly using protective equipment.   According to that line of thought, poor Nina Pham simply did not know what she was doing when she picked up a touch of Ebola from her patient.  If only she had more education on how to put on gloves and a gown, this whole disaster could have been avoided.

I think not.

I posted my dismay regarding re-educating nurses on FaceBook and was amazed at how smart my friends are.

One non-nurse, Michelle said that education was a way to protect the facility.  In other words, when a policy is violated, the hospital is able to assure any surveyor or lawyer that they did, indeed, provide the education and training and have therefore met their responsibility.  Sadly, a successful healthcare facility (and by successful, I mean isn’t closed down) must cover all bases to minimize damages.  I would probably waste time and resources re-teaching PPE, too if I had to make the decisions.

She also pointed out that maybe protocols are not strictly enforced when the risks are lower which could lead to bad habits.  I agree.  Ever notice how MRSA is already a problem when we start monitoring hand hygiene?  (I love that.  Hand hygiene – soon there will be an aisle in the supermarket for hand hygiene products instead of soap, antibacterial gel and hand lotion.)

Lisa Selman Holman pointed out how very miserable PPE is to wear.  She is right.  It is hot and sticky, nothing fits right and it is ugly in the most unforgiving way.  I have yet to figure out how looking like Big Bird assists in the infection control process. Healthcare workers, especially those with a fashion sense, can’t wait to take it off.

If ever there was a time to spend money, this would be it.  Athletic clothing manufacturers have done amazing things with sports gear.  It seems like a clothing manufacturer who exists because they make comfortable, functional clothes that can wick away perspiration, kill enough germs to smell good and keep a body warm in water might be able to help design something comfortable, disease proof, easily taken on and off  with the assistance of an infection control specialist.

Sara Kawaguchi came up with the idea of having two people involved – one present simply to observe.  I love this idea and it is cheap to do when considering the stakes.  Having never met Miss Pham, I can only assume that she didn’t tear a glove, look at it and say, ‘Oh darn,’ and carry on with restarting an infiltrated IV line.   If she breached protocol, it was likely unnoticed by her.

My cousin, Steve, is a physician and his response was simple.

1) we are human
2) we make mistakes
3 there is no room for a mistake here, in flight or in surgery

There’s a lot of truth in that but we can minimize mistakes.  Even the world famous Quality Assurance plan designed by Toyota, Six Sigma refers to only six errors in a million.  When it comes to Ebola, nobody wants to be one of the six.

The Checklist Manifesto by Atul Gawande is written by a surgeon who almost killed a patient because he forgot to do something very simple and standard prior to surgery – type and match blood.  After this near catastrophe that left his confidence shaken, he set about researching how to prevent errors.  It turned out that aviation history was marred by the crash of the first B17 in which several people died.  It almost took Boeing aircraft out of the game completely.  The solution included a checklist which enabled the (highly skilled and trained pilots) to fly 12 planes a total of 1.8M miles without incident.  It is now used universally.

Checklists are not designed to educate anyone.  If you have ever turned in visit notes only to find out that you forgot to write a narrative because you were interrupted, you are prone to human error.  If you have ever been called about a bill you know you paid only to find the stamped envelope in your purse, you could have used a checklist.  They are designed to let you pick up where you left off in the event something slips your mind, you are preoccupied or there is chaos all around you.  They ground and center the user.

There are undoubtedly numerous approaches to improving the safety of healthcare workers but re-educating the staff in a critical care unit on how to put on and take off PPE is an intervention for the hospital – not the nurses.  Don’t tell me that the staff in an intensive care unit requires more schoolin’ to put on gowns, masks and gloves.  Make them more comfortable so they aren’t urgently ripped off like they were on fire the minute you clear the room.  Have someone else watch.  Use a check list.  Doing more of what was done in the past because it didn’t work doesn’t quite make sense to me.

What the healthcare staff needs the most is a cure for Ebola.  When it comes to caring for a patient with Ebola, especially at the end of life, perhaps the most important changes will come about from the staff who were actually there doing the job.  If the blame game stops and the focus is directed to increased protection of healthcare workers, why not consult that handful of clinicians who are the only ones in the United States to have cared for Ebola patients in US hospitals?

I know that you join The Coders in wishing Godspeed to Nina Pham’s recovery.  She was able to be there for a patient isolated from his family and friends when he needed them the most.  People like Nina Pham do not put their own lives on the line for a paycheck.  She has a calling and I pray she will be back at work sooner than later.

Also,  let’s not forget that Nina Pham is not alone.  A few dozen other healthcare workers who took the same risk as Nina Pham and so far, have been free of symptoms.  These include the staff in Dallas as well as Nebraska and GA where two other Ebola patients have been treated.  They are no less heroic because they have not contracted Ebola; they just haven’t made the news and I hope they don’t any time soon.

Ebola? Here in the States?


 

It looks like we have company in the form of another virus.  Ebola has caused quite a stir in the US and the media is torn between reporting it as a benign little incident so insignificant as to not warrant our attention and predicting Armageddon.  With all new viral pathogens, it is difficult to predict.  A virus will do what it can to survive and most times that means reducing the severity of the illness so as not to kill its host and prolonging the incubation period.  Who knows what Ebola will do.

If 40,000 fatalities from Ebola were predicted this year, there would be mass panic.  If there was a preventative measure, who wouldn’t do what they could to get it  no matter what the cost? 

We are looking at close to 40,000 deaths from flu and pneumonia this year.  There are legitimate questions about these statistics such as why are flu and pneumonia lumped together as the 8th leading cause of death?  They are not the same disease.  To dispel the statistical arguments, lets pretend that only 20,000 deaths will result from the flu this year.  Tragically, most cases of the flu are preventable at no cost to most people.

Setting death aside for a minute (or hopefully many years), consider the experience of having the flu.  The first day or so, patients are afraid they are going to die.  As it reaches its peak, they are afraid they will not die.

We don’t want our patients to feel like that.   Many home health patients will end up in the hospital if they get the flu.  Hospice patients may be terminal but most have plans to die from something less miserable.  It is okay to get between the flu and your hospice patient. 

So, while we are panicking about Ebola, let’s keep in mind that there are thousands of lives we can save with a simple flu shot.  The CDC has a ton of free resources that you can use in your agency, patient homes, and community to promote vaccination.  Most have room for your company logo and the CDC is fine with you adding it.  Think about it.  When was the last time that the government provided you with professionally designed materials to be used in promoting your agency or hospice? 

When we figure out what we can do about Ebola, we’ll post it here.  Until then, get out there and stick as many old people with needles as you can.  Here are some codes you can include on your care plan if you know upon admission that you will be giving a flu vaccine.

  • V03.82 Vaccine for Streptococcus Pneumonia (PPV)
  • V04.81 Vaccine for Influenza Virus
  • V06.6 Streptococcus pneumoniae [pneumococcus] and influenza

Is anyone qualified to write or help us write a short blog on how to bill for the flu and pneumonia vaccines?  Let me know below or by emailing TheCoders@hhcoding.com.

Elderly Abuse?


A colleague of mine got a couple of phone calls from patients terrified they were going to be admitted to a nursing home.  Two men had come by with a three page list of questions and started asking very personal questions about whether or not they can get in a car, if they can go out to eat and how often their nurse visits.

My colleague reports in his email to me:

“They are not leaving cards or anything. One savvy patient finally got all their information and called us with it.”

and

“One patient was not home when they stopped at his house so they talked with and asked his neighbor questions.”

The men in question were employed by Jackson Dunham Sato & Associates. If you glance through the bio’s on the left sidebar, you will see that essentially all of the managers, partners and associates mostly come from one of two federal governing bodies – the OIG, and CMS (Medicare).  In fact, if you go to the top bar and click on careers, you will find that they are not interested in you if you are not:

  • A current or former Office of Inspector General Auditor/Investigator with healthcare experience
  • A current or former CMS employee who has been involved in program compliance/integrity oversight

At least you don’t have to worry about them poaching your employees.

I realize and you probably do, too, that all of this information is second and third hand.  In order to be responsible, I emailed each of the three senior partners and have not received a response.  The questions asked of them were:

  1. Is this your usual policy regarding identification of your investigators on home visits?
  2. Would it be possible to have your folks dress down; perhaps wear scrubs?
  3. What explanation is given to the patients if they do not ask for identification?  Do the investigators allow them to make assumptions no matter how terrifying?
  4. Do you understand that a patient fearful of nursing home placement might exaggerate their functional abilities?
  5. Could you or do you leave some sort of documentation with the patients?  Patients are calling agencies who are unaware of your presence and cannot offer the patients any reassurance because they do not know who interrogated their patients.
  6. Do you ever send clinicians out to the home to verify medication use and evaluate gait and balance?
  7. Do you do a mental status exam on the patients?  Many patients with Alzheimer’s Dementia and other organic brain syndromes appear as right as rain the first couple of times you meet them.
  8. How do you choose the providers you will be investigating?   Are they assigned to you by Health Integrity?  Do you have access to databases that you can mine for data?
  9. How are you paid by Health Integrity?  Is your payment predicated in any way on recouped monies or arrests?

I have not gotten a response but Health Integrity, LLC confirms that Jackson Dunham, Sato and Associates are a ‘partner’ on their website.  Health Integrity, LLC is the Zone Program Integrity Contractor (ZPIC) for CMS Regions 2 and 4.  Combined, these two regions encompass  Alaska, Arizona, Colorado,  Idaho, Iowa, Kansas, Missouri, Montana, Nebraska, New Mexico, Oklahoma,, North Dakota, Oregon, South Dakota, Texas, Utah, Washington, and Wyoming.

Regardless of an agency’s guilt or innocence, our elderly deserve to be treated with more respect than they have been shown by Jackson Dunham Sato and Associates.  I question the motives of a firm that resorts to intimidating elderly patients and possibly encouraging them to exaggerate their functional abilities in order to ‘prove’ that a patient is not homebound.  Are they genuinely concerned about the welfare of our elderly and protecting the trusts that fund Medicare or are they simply trying to satisfy a requirement for contract renewal, bonus pay or something else?

I can sit at my desk a thousand miles away from a patient and know whether or not their homebound status is questionable.  It is tedious to read every note, every MD clinic visit and OASIS assessment to look for discrepancies and the tell tale signs that the patient does not fit the description in the care plan and the visit notes.   It is not the most glamorous job in the world, I assure you but it can be done without instilling fear of unwanted nursing home placement in elderly people.  Even if a visit has to be made in order to make a final determination, it does not require rudeness or fear.  Even if the investigators are accompanied by a nurse from the agency, it is unlikely that a nurse would be able to influence the patient to lie.

The very best consultant and the very best lawyer cannot help you if you are determined to play outside of the conditions of participation and conditions for payment.  We’ll take you money and do our best. If it is a question of inadequate documentation versus fraud, we can generally help but there is not much we can do if you simply choose to sidestep the rules.

Nobody who works for Medicare or is contracted or subcontracted by Medicare seems to understand that good providers have even less tolerance for the fraudulent providers than they do.  If they would make just the tiniest effort to work with the majority of providers who are good, they might learn a thing or two and then it wouldn’t take years and hundreds of millions of Medicare dollars gone before they caught up with the truly bad players.  At that point, they could offer more frequent education to those providers who take compliance seriously.

If your patients have had visitors or if you have had experience with Jackson Dunham, Sato and Associates, please email me privately and let me know.  As always your comments are welcome below and if I get a response from Jackson Dunham, Sato and Associates, I will be sure to let you know.

One last thing….. if I ever hear of you intimidating a patient, watch out.  I am not nice when I hear of an elderly person treated with anything less than respect.

This Just (snuck) In!


Hospice Providers, take note

To be quite honest, I have never seen a ‘no code’ list in hospice.  If anything, I would expect to see a ‘full code’ list as any code status besides DNR would be the exception.

And yet, there is a new list of codes that hospices may not use when determining the primary reason for hospice care.   A list of codes at the end of this document will be automatically returned to providers when used as a principle code for hospice for claims billed after October 1.

This information comes from CMS change request 8877 which also contains very important information about the Notice of Election.

Home Health Providers:

An updated Local Coverage Determination has been published by Palmetto GBA for Alzheimer’s Dementia.  Among the insightful gems included in this guidance is the following passage begging the question of, ‘does someone have too much time on their hands?’

Behavioral disturbances often complicate the medical management of beneficiaries with Alzheimer’s disease. At baseline many individuals with Alzheimer’s disease manifest activity limitations in such domains as communication and self-care. The occurrence of behavioral disturbances, if not addressed in a comprehensive and systematic manner, may further compromise the activity limitations present at baseline – resulting in sub-optimal clinical outcomes.

Wow.  I’m glad we cleared that up.  Seriously, look how often the word, ‘baseline’ is used.  If you really want to get paid, consider using the FAST scale to stage Alzheimer’s on admission and recert.  There are also numerous documentation requirements.  Please review and document accordingly.

If you recall, numerous claims once denied for Face-to-Face documentation are now being denied for lack of both long and short term goals.  The reference to short and long term goals is listed as the Physical Therapy LCD.  I am quite certain that the Alzheimer’s documentation LCD will be used in the same way.

Both of these regulations will take place on October 1.  Be ready.

 

The Hospice No Code List

290.0 Senile Dementia Uncomplicated
290.10 Presenile Dementia Uncomplicated
290.11 Presenile Dementia With Delirium
290.12 Presenile Dementia With Delusional Features
290.12 Presenile Dementia With Delusional Features
290.13 Presenile Dementia With Depressive Features
290.20 Senile Dementia With Delusional Features
290.20 Senile Dementia With Delusional Features
290.21 Senile Dementia With Depressive Features
290.3 Senile Dementia With Delirium
290.3 Senile Dementia With Delirium
290.40 Vascular Dementia Uncomplicated
290.41 Vascular Dementia With Delirium
290.42 Vascular Dementia With Delusions
290.43 Vascular Dementia With Depressed Mood
290.8 Other Specified Senile Psychotic Conditions
290.9 Unspecified Senile Psychotic Condition
293.0 Delirium Due To Conditions Classified Elsewhere
293.1 Subacute Delirium
293.81 Psychotic Disorder With Delusions In
293.82 Psychotic Disorder With Hallucinations In Conditions Classified Elsewhere
293.83 Mood Disorder In Conditions Classified Elsewhere
293.83 Mood Disorder In Conditions Classified Elsewhere
293.83 Mood Disorder In Conditions Classified Elsewhere
293.83 Mood Disorder In Conditions Classified Elsewhere
293.83 Mood Disorder In Conditions Classified Elsewhere
293.83 Mood Disorder In Conditions Classified Elsewhere
293.89 Other Specified Transient Organic Mental Disorders Due To Conditions Classified Elsewhere
294.20 Dementia, Unspecified, Without Behavioral Disturbance
294.21 Dementia, Unspecified, With Behavioral Disturbance
294.8 Other Persistent Mental Disorders Due To Conditions Classified Elsewhere
294.8 Other Persistent Mental Disorders Due To Conditions Classified Elsewhere
310.0 Frontal Lobe Syndrome
310.1 Personality Change Due To Conditions Classified Elsewhere
310.2 Postconcussion Syndrome
310.89 Other Specified Nonpsychotic Mental Disorders Following Organic Brain Damage
310.9 Unspecified Nonpsychotic Mental Disorder Following Organic Brain Damage

Hospice Medications – Who Pays for What?


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Hospice Providers, it’s time to take your head out of the sand!  Medicare keeps writing long memos about who pays for what medications and I still keep hearing that the hospice only pays for pain medications.  The information below was taken from the Medicare Memo issued last week.

  1. You don’t get to exclude all meds and care not directly related to the terminal condition. Supposedly this has always been the case.
  2. You cannot exclude medications that are used for the comfort and palliation of symptoms no matter what.  If a patient is admitted for end stage heart failure and has arthritis, you must pay for arthritis medications as well.
  3. Prior authorizations for Medicare Part D will be required and they must include the reason why the medication is not covered under the hospice benefit.
  4. Medications that are paid for after the patient elects the hospice benefit but before the pharmacy has been notified will fall into some sort of limbo land and the pharmacy will have to collect from the hospice – or the patient.  Any UFC fans out there?
  5. If a patient wants a specific drug that is not one your formulary and the patient refuses to try medications that are on your formulary, you can refuse to provide them.  Alternatively, you can provide them and bill the patient if you have a signed advanced beneficiary notice.
  6. Patients have the right to appeal your decision.

If you want to survive this maze, the first thing you need to do is to approve a formulary.  This is a list of drugs you may potentially be required to provide over and above the standing orders for pain meds.  Personally, I would start with one of those $4.00 drug lists from a chain drug store.  They all have one.

Hospice nurses must have frank discussions with patients and caregivers at the time of admission.  In truth, there is no way to determine if a medication is for palliative relief of symptoms until the patient is assessed.  In talking with patients and caregivers, the emphasis should be on symptoms.  Some individuals with diabetes are very uncomfortable when their blood sugar goes up beyond a certain point.  Other people can sport a blood sugar of 550 without symptoms.  Blood pressure is usually asymptomatic but strokes are not.  If a patient has suffered a prior neurological insult, the safest thing to do would be to find a cheap drug and treat it for less than 10.00 per month.

Nice hospice providers will alert their contracted pharmacy to a hospice admission as soon as it is known for sure that a patient will be admitted.  This will prevent those limbo drugs where everyone is fighting over who pays.  This process is recommended but not mandated (I think…) in the new CMS guidelines published last week.

People are funny about their medications.  If a patient refuses to try Prilosec and opts for Dexilant at 20 times the cost, work with the patient.  Ask for samples and assist the patient in getting the best price for the medication of choice.

Maybe the most disturbing aspect of the new guidance from CMS is the involvement of the patient and families.  Part D pharmacies are advised to bill family members for medications that were inappropriately filled.  Hospices with limited (if any) formularies will attempt to pass the cost off to the patient.  Although the patient has the right to appeal the logistics of a hospice patient or family member appealing to Medicare strike me as utterly incongruent with the fundamental purpose of hospice which is to allow a patient to die at home in peace.

I have not seen as yet the proposed consequences to a provider who simply tells the patient Medicare won’t cover something without explaining all of the details, alternatives, etc. I think good hospices will put a blank appeal form in the home folder for the patient.  Bad hospices will go out of their way to avoid telling patients and family members that an appeal is possible.

Meanwhile adopt a comprehensive formulary and start today advising the patient what you will pay for, the reason it will given (comfort) and what you will not be giving.  It may cost you a few patients but I guarantee those that don’t put these processes into place will lose more than a patient or two.

Good luck with all this, you hear?