Healthcare Rules: Hospice Face-to-Face Requirement

Similar to home health face-to-face requirement, hospice too has one. Again, this is a change to the hospice certification requirements, a little different than the home health face-to-face requirement but again, the point is the same. Read this expert information provided by our speaker in a hospice conference.

This is an anti-fraud prevention that's included within the mini anti-fraud prevention as part of Healthcare Reform in the PPACA legislation. And this is again designed to get to patients where they think patients who really don't meet that six-month terminal illness requirement are still being certified for hospice by the physicians and receiving services they're not really eligible for. And so the point here is to again get the physician involved in assessing the patient and signing off in detail on the patient's terminal illness.

The first thing to note here, unlike with the home health certification, physicians are going to be required to perform the face-to-face visit for patients reaching the third benefit period. So this doesn't come in at the front end on hospice hospital. This comes in if you're into the third benefit period or longer.

Now, that's a change. The way they worded it in the proposed rule and now they're a little different, it kicks off with the third benefit period. So you've got a pretty clearly marked starting point.

If you've got a terminally ill patient who's going to make it, looks like they're going to be needing to be recertified that third benefit period, you now need to be thinking about, “We have to have a physician face-to-face visit”.

In response to some of the comments about the burden imposed by this face-to-face requirement, CMS noted, “We don't think most hospice patients require this face-to-face visit because they're not going to make it to the third benefit period.” So you may find this doesn't count as often in hospices and home health but it's still out there as per CMS rules.

Now, when do you have to do it? If you've got a patient that's approaching third benefit period, the initial face-to-face encounter may occur no more than 30 days prior to the third benefit period. So the flag should pop up for you at 30 days prior to the third benefit period.

Then, if the patient is continuing on hospice hospital past that third benefit period, you're going to keep doing the face-to-face prior to recertification. And again, the deadline is going to be no more than 30 days prior to each recertification. So it's always recert minus 30 until such time as the patient either leaves hospice or passes away.

Now, something to know about the “when”, if your patient transfers during the third or subsequent benefit period, you may not need to do the face-to-face if the transferring hospice has already done it.

So if you receive a patient going into the third benefit period and the other hospice in anticipation of the arrival of the third benefit period or prior to the start of the third benefit period performs that face-to-face encounter and has the documentation we're going to talk about in a second, you won't need to do the face-to-face for that benefit period.

Now, if the patient is transferred to you and then we're moving to the third benefit period and on to the fourth benefit period, obviously at that point we're recertifying for an additional benefit period after the third. Now it's your obligation as a provider to do the next face-to-face according to the home health rules.

And so the point here is you might save yourself at least the first face-to-face visit, depending on the timing of transfer and whether or not the face-to-face happened prior to that transfer.

Now, what is the purpose of this face-to-face? The purpose somewhat similar to the home health face-to-face is to gather clinical findings to determine the patient's continued eligibility.

So the physician who is going to meet with or the non-physician practitioner who's going to meet with the patient is gathering information to use to support their clinical determination that the patient is continuing to be certified as terminally ill.

Now these listed individuals who can perform the face-to-face are the physician or nurse practitioner. The physician must be employed by or under contract with the hospice. As per the CMS rules, the hospice physician – not the attending physician – should be the one who performs this face-to-face.

So your medical director, et cetera; because of the nature of the care et cetera and also to avoid the potential for an outside physician who's willing to fudge things to keep a person eligible even if maybe they're not. So it has to be a physician that you've either employed or you have a contract with such as your medical director.

And the physician who performs the face-to-face encounter must also compose the narrative and sign the certification. So you can't have your doctor performing the face-to-face and then give the information to another doctor to do the narrative and sign it off or in the case where you have two hospice physicians.

Now, if you have a nurse practitioner who performs the face-to-face, the certification has to be signed by a physician. So the rule allows, if the nurse practitioner does the face-to-face, the nurse practitioner will then document his/her findings and transmit those findings to the physician.

The physician will then use those findings to document the determination and then to do the certification as per healthcare guidelines. And in that case, then that's really a situation where you're going to have somebody different signing the certification then performing the face-to-face.

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