Certification that are accurate and timely are a key element in managing a compliant hospice agency. Certifications are not only for medical record compliance and proper patient care, but also impact the efficiency and success of the billing department to get claims paid in a timely manner.
Hospice Benefit Periods
First, we have to define the requirements for someone to be eligible for hospice care.
Every patient before being admitted to hospice must be qualified as terminally ill with a prognosis of having 6 months of life or less. This prognosis can only be determined by a physician. Nurses or NP cannot certify a patient as terminally ill with a prognosis of 6 months or less.
The hospice benefit does not expire. The certification is based on the patient prognosis, but life is not a textbook. Although the standard assumes all else being equal this patient’s terminal diagnosis is a life expectancy of no more than 6 months, people often live on hospice far longer. The certifications are designed to regularly renew that prognosis and ensure the patient, as of now, has a prognosis of 6 months or less.
The initial certification done at the start of care is documented in two forms:
- The Verbal Physician Certification of Terminal Illness – typically completed by the nurse
- The Hospice Physician Certification of Terminal Illness where the physician, based on the nurses narrative, confirms and signs off on this prognosis and officially admits the patient into hospice.
For flexibility and ease of use, we designed these forms to match different workflows and clinicians’ availability allowing your teams to complete the certification with multiple signers in one form or broken out into two separate forms.
Timeline of Certifications
The Hospice benefit is broken into 2 types of benefit periods. The first benefit period is their initial benefit period in which a patient receives two 90-day benefit periods in total. In total meaning if someone revokes or is discharged and then comes back on care, their benefit periods resume for the full remaining days of the benefit allotment.
The second type of benefit period are the 60-day benefit periods, which are unlimited as the hospice benefit never expires. The 60-day benefit runs every 60 days following the end of the 2nd 90-day benefit period.
Certification of 2nd 90-day benefit period
Before the start of the 2nd 90-day benefit period the Hospice Physician Certification of Terminal Illness needs to be completed the Hospice physician to again certify terminal illness.
The 60-day benefit periods certifications only have to be completed by the Hospice physician and not an attending.
A hospice must receive verbal or written certification 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 by the hospice within 2 calendar days, verbal certification must be obtained. The hospice must determine who may accept verbal certification from a physician in compliance with regulations.
If the patient is entering into to their third or later benefit period, the hospice physician (or hospice-employed nurse practitioner) must conduct and complete the Face-To-Face Encounter Attestation no more than 30 days prior to the start of the benefit period. Alongside the F2F, the physician must again complete the Hospice Physician Certification of Terminal Illness.
Another helpful form is the Nurse Recertification. This is not a regulatory required form but is completed by the nurse and often used by the hospice physician to develop the narrative portion of the certification.
In addition, the hospice must ensure the written certification/recertification is signed and dated prior to billing Medicare, or their claim may be denied.
- Must include a patient narrative explaining why that patient qualifies for hospice detailing the prognosis by the MD or attending physician and an attestation statement.
- Must be signed and dated by the physician
- If the narrative is part of the initial cert form, then it must be located directly above the physicians signature
- The narrative must be completed by the certifying hospice physician
- Must state then benefit period dates that the cert of recert covers.
For initial cert- Signature must be signed by the hospice physician or physician as a member of the IDG and the attending physician.
For recerts. – only the hospice MD or physician from the IDG is required to sign, the attending physician doesn’t have to sign.
Typical errors that can cause certification issues and lead to billing rejections from claims for Medicare may include:
- Physician signatures are missing
- Predating physician cert signatures
- Attestation and narrative are missing
- Date of signature is missing
- Hospice physician and/or attending signatures are missing from initial cert.
- Recert is not completed within specific time frame
All of these easy mishaps could lead to pitfalls like an auditor flagging you for numerous compliance issues which can lead to serious repercussions such as non-payment or even the forced discharge of patient from your agency’s care.
With forms that are simple to complete, provide historical trends within the forms, and auto-flow of information from previous documentation, we’ve made certifting and recertifying a seamless process. Find out how our flex forms library helps clinicians get organized and complete their documentation quickly and efficiently.
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