Enhance your mission and side-step your compliance apprehensions for good with these expert solutions provided by our expert in a hospice conference.
Question: You wish to offer a palliative care program for people who do not qualify or do not wish to enroll in hospice. You would like it to look the same as a hospice and would bill Part B, why would you have to charge anything in addition to Part B?
Answer: A lot of hospices would like to offer of a mirror image of their hospice program but the problem is that Part B will pay for physicians and nursing practitioners.
The Part B program might in some very limited circumstances pay for social workers. That’s more in the cycle therapy realm so it usually doesn’t come into play very much in the palliative care program. And they won't pay for anything else.
So, if the hospice wants to develop, you know, they could become a Part B provider and they could bill Part B. They can also bill private insurance for the physician and the nursing practitioner. And then when there is no private insurance and Medicare and of course Medicaid also. They can bill Medicaid. But if there are none of those, they should be billing the patient.
Now, when you add on the additional services of the, as mentioned by our expert in the hospice conference, the volunteer support and the chaplain and the social worker, OT, PT, speech, you know, whatever else is being added to the mix, then you have a problem because there’s no reimbursement stream.
You probably will get some private insurance to pay for it. But in the absence of Medicare reimbursement, you're going to have to bill that somewhere. And so, it can be done but you have to bill the patient for those parts of the IDT model, palliative care program that are not being picked up anywhere else.
Question: If you are intending to obtain a large grant to pay for our palliative care program, is this permissible?”
Answer: The short answer is, “Yes.” And then there’s a but. So, how this works is of course, hospices can get grant money to augment their hospice programs and also their palliative care programs. The problem is that simply getting the grant let's say - let's use an example.
If the hospice wants to provide a full IDT palliative care model for people who do not need the six-month prognosis. They have a life expectancy of more than six months. And you want the get a grant to do the full IDT model, you can get some money to do that but the problem is that if you don't still bill fair market value to somebody, then you still have the problems of inducement to beneficiaries who might later come into your Medicare hospice program guidelines.
So, the way that grants can work the best is if they supplement your charity care. So, if you say, “We’re going to bill for this program but we are going to understand that many people cannot afford it. So, we’re going to have a liberal sliding scale. And those people who truly cannot it, we’re going to get a grant to pay for them. Those people who can afford it, they're going to pay.” And then you have a sliding scale. So, most people are going to be paying something for those items that are not covered under Medicare guidelines, Medicaid or private insurance.
Question: Why a hospital can have a palliative care program under its license but that possibly a hospice would not be able to under its state licensure laws?
Answer: This is something that seems very unjust. And it feels that way to me too. And the problem really though is that hospice licensure laws and regulations get very precise about the definitions of what hospice is and what terminal illness is.
Now, in many states, Massachusetts for example has some very liberal laws that, you know, you just don't have to worry about your definition of hospice. And it's quite easy to set up a palliative care program. In other states like California, they actually had to change their regulations to be able to do any sort of palliative care program at all. And then we have, you know, lots of other examples all over the map.
But in many states it's okay. Many states, it's clearly not okay. And you have to find the work around. And then in other states it's a little gray. And that’s why don't necessarily go into your state agency and ask them what they think about this because they probably haven't thought about it and you might get an answer that you don't like. So, it's very important to study and work with your state associations.
But it is because of those definitions in the state licensure laws and regulations, we don't have similar definitions for hospitals. And so since there is no - at least to my knowledge, there is no place in the country where palliative care is so defined and circumscribed in law that other healthcare providers could not provide it under their license. So, you actually can have a lot of different kinds of healthcare providers and specifically hospitals as hospice or who are setting up palliative care programs because they have no prohibitions. It seems unfair but there are some things we can do to work around it.
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