Introduction to Hospice Regulatory Requirements

As hospice nurses and clinical/billing managers, you play a crucial role in ensuring that your organization provides high-quality care while complying with federal regulations. Let’s break down the critical regulatory requirements you need to know to excel in your role and provide the best possible care for your patients.

Why are hospice regulations necessary?

  • Ensure consistent, high-quality care across all hospice providers
  • Protect patients’ rights and dignity
  • Maintain standards for safety and comfort
  • billing practices to prevent fraud and abuse

Critical regulatory bodies and documents:

  1. Centers for Medicare & Medicaid Services (CMS)
  2. Code of Federal Regulations (CFR), specifically 42 CFR Part 418
  3. State-specific hospice regulations

Core regulatory areas for hospice providers:

AreaKey Requirements
Patient EligibilityTerminal illness certification, life expectancy of six months or less
Election of Proper documentation, explanation
Plan of CareInterdisciplinary development, regular updates
Service DeliveryCore services provision, contracted services management
Quality Assessment and Performance Improvement (QAPI)Ongoing data collection and analysis, improvement initiatives
Billing and ReimbursementAccurate coding, timely submission of claims

Critical timelines to remember:

  1. Initial Certification: Must be completed within two days of admission
  2. Comprehensive Assessment: Within five calendar days of the election
  3. Updates to Plan of Care: At least every 15 days
  4. Recertification: Every 90 days for the first year, then every 60 days after that
  5. Face-to-Face Encounters: Required for recertifications after the first 180 days

Critical responsibilities for hospice staff:

  • Nurses:
    • Conduct initial and comprehensive assessments
    • Provide skilled nursing care
    • Coordinate with other team members
    • Document care accurately and in a timely manner
  • Clinical Managers:
    • Ensure compliance with care delivery standards
    • Oversee interdisciplinary team meetings
    • Monitor quality metrics and implement improvements
    • Manage staff education and competency
  • Billing Managers:
    • Ensure accurate coding and billing practices
    • Submit timely claims and respond to audits
    • Stay updated on reimbursement policies
    • Coordinate with clinical staff to ensure documentation supports billing

Best practices for maintaining compliance:

  1. Implement robust internal auditing processes
  2. Provide ongoing staff education on regulatory requirements
  3. Use technology to streamline documentation and billing processes
  4. Stay informed about regulatory changes and updates
  5. Foster a culture of compliance within your organization

Remember, these regulations ensure that hospice patients receive the highest quality of care during their end-of-life journey. By understanding and adhering to these requirements, you’re not just following rules – you’re helping to provide compassionate, patient-centered care that respects the dignity of each individual you serve. Stay vigilant, keep learning, and don’t hesitate to seek clarification when needed. Your commitment to regulatory compliance directly contributes to your patients’ well-being and your hospice organization’s success.

Initial Certification Process

Timing and Documentation

The initial certification process is critical in ensuring hospice patients receive the care they need while complying with federal regulations. Here’s what you need to know about the timing and documentation requirements:

Timing Requirements:

  1. Initial Certification:
    • Must be completed within two calendar days of the start of .
    • It can be completed up to 15 days before hospice care is elected.
  2. Verbal Certification:
    • If written certification cannot be obtained within two days, a verbal certification must be obtained within the same timeframe.
    • The written certification must be on file before submitting a claim to Medicare.
  3. Recertification:
    • Must be completed up to 15 days before the start of the following benefit period.
    • Required every 90 days for the first year, then every 60 days after that.

Documentation Requirements:

  • Written Certification:
    • Must include a statement that the patient’s medical is for a life expectancy of 6 months or less if the illness runs its normal course.
    • The hospice medical director, an interdisciplinary group () physician member, and the patient’s attending physician must sign and date.
  • Verbal Certification:
    • It must be documented in the patient’s medical record.
    • The written certification must follow and be on file before billing.
  • Clinical Information:
    • It must support the and be included in the patient’s medical record.
    • Initially, clinical information may be provided verbally and documented in the record.

Physician Narrative and Attestation

The physician narrative and attestation are essential components of the certification process. They provide the clinical basis for the patient’s prognosis and ensure compliance with regulatory requirements.

Physician Narrative:

  • Content:
    • A brief narrative explains the clinical findings supporting the patient’s six months or less life expectancy.
    • The certifying physician must write it and cannot include checkboxes or standard language for all patients.
  • Placement:
    • If part of the certification form, it must be located immediately above the physician’s signature.
    • If an addendum is required, the physician must sign the addendum immediately following the narrative.

Attestation:

  • Statement:
    • The narrative must include a statement attesting that the physician composed the narrative based on their review of the patient’s medical record or examination.
    • This attestation must be located above the physician’s signature and date.
  • Common Errors:
    • Missing or incomplete attestation statements.
    • Missing physician signatures or dates.
    • Predating signatures or using standard language for all patients.

Key Responsibilities for Hospice Staff:

  • Nurses:
    • Conduct initial assessments and gather clinical information.
    • Coordinate with physicians to ensure timely certification.
    • Document verbal certifications and follow up for written certifications.
  • Clinical Managers:
    • Ensure compliance with certification and documentation requirements.
    • Oversee the interdisciplinary team’s coordination and communication.
    • Monitor and address common certification errors.
  • Billing Managers:
    • Verify that all required documentation is complete and accurate before submitting claims.
    • Ensure timely submission of certifications to avoid payment delays.
    • Stay updated on regulatory changes and educate staff accordingly.

Summary Table

RequirementTimingDocumentationResponsible Parties
Initial CertificationWithin two days of hospice care start, up to 15 days beforeWritten certification with prognosis, signed and datedHospice medical director, attending physician
Verbal CertificationWithin two days if written, not possibleDocumented in the medical record, followed by writtenHospice staff, certifying physician
RecertificationUp to 15 days before the next benefit periodWritten certification with prognosis, signed and datedHospice medical director, IDG physician

By understanding and adhering to these requirements, you ensure that your hospice organization remains compliant and that your patients receive the compassionate, high-quality care they deserve. If you have any questions or need further clarification, don’t hesitate to contact your compliance team or regulatory resources.

Ongoing Patient Care Requirements

As hospice professionals, you are crucial in providing compassionate, high-quality care to patients and their families. Let us explore two key aspects of ongoing patient care: Registered Nurse Case Manager Visits, Plan of Care Updates, and Interdisciplinary Team Meetings.

Registered Nurse Case Manager Visits

Registered Nurse (RN) Case Manager visits are essential for assessing patient needs and ensuring quality care. Here are the key points to remember:

Frequency of Visits:

  • RN visits must occur at least every 14 days
  • More frequent visits may be necessary based on the patient’s condition

Purpose of Visits:

  1. Assess the quality of care provided by hospice aides
  2. Ensure services meet the patient’s needs
  3. Evaluate the patient’s condition and update the plan of care as needed

Documentation Requirements:

  • Document each visit thoroughly in the patient’s medical record
  • Include assessments, interventions, and any changes in the patient’s condition

Best Practices:

  • Schedule visits proactively to ensure compliance
  • Use a checklist to cover all necessary aspects of care during each visit
  • Communicate findings and concerns to the interdisciplinary team promptly

Plan of Care Updates and Interdisciplinary Team Meetings

Regular updates to the Plan of Care (POC) and Interdisciplinary Team (IDG) meetings are crucial for providing comprehensive, patient-centered care.

Plan of Care Updates:

  • Must be reviewed and revised at least every 15 calendar days
  • Should be individualized to meet the patient’s and family’s needs

Interdisciplinary Team Meetings:

  • Typically held weekly or bi-weekly
  • Must include representatives from nursing, medicine, social work, and pastoral or spiritual counseling

Key Components of an Effective POC:

  • Patient and family goals
  • Interventions based on identified problems
  • All services necessary for palliation and management of the terminal illness
  • Measurable outcomes
  • Medications, treatments, and medical supplies needed

IDG Responsibilities:

  1. Develop and maintain the POC
  2. Provide or supervise hospice care and services
  3. Establish policies and procedures for the provision of hospice care
  4. Assess and address the comprehensive needs of patients and families
POC ElementDescriptionFrequency of Review
Patient GoalsSpecific, measurable objectives for careEvery 15 days minimum
InterventionsDetailed actions to address patient needsEvery 15 days minimum
MedicationsCurrent list with dosages and frequenciesEvery 15 days minimum
ServicesScope and frequency of all Every 15 days minimum

Best Practices for POC Updates and IDG Meetings:

  • Use a standardized format for POC documentation
  • Ensure all team members contribute their expertise
  • Document team discussions and decisions thoroughly
  • Follow up on action items from previous meetings
  • Involve the patient and family in care planning when appropriate

Remember, these ongoing care requirements are designed to ensure that our patients receive the highest quality of care. By staying diligent with RN visits, POC updates, and IDG meetings, we can provide compassionate, comprehensive care that makes a difference in our patients’ lives. As hospice professionals, your dedication to these practices ensures regulatory compliance and demonstrates your commitment to excellence in end-of-life care. Don’t hesitate to contact your supervisors or compliance team if you have any questions or need support in implementing these requirements.

Recertification Process

The recertification process is crucial for ensuring continued hospice care for eligible patients. As hospice professionals, understanding this process is essential for providing uninterrupted, high-quality care while maintaining compliance.

Medical Director’s Written Recertification

The medical director’s written recertification is a key component of the recertification process. Here are the crucial points to remember:

Timing:

  • Must be completed up to 15 days before the start of the following benefit period
  • Required every 90 days for the first year, then every 60 days after that

Requirements:

  1. Statement confirming the patient’s prognosis of 6 months or less
  2. A brief narrative explaining clinical findings supporting the prognosis
  3. Physician’s signature and date

Best Practices:

  • Use a standardized form to ensure all required elements are included
  • Review the patient’s most recent clinical documentation before writing the narrative
  • Avoid using generic language or checkboxes

Verbal Certifications: When and How to Use Them

Verbal certifications can be used when written certifications are not within the required timeframe. Here’s what you need to know:

When to Use:

  • If written certification cannot be obtained within two calendar days of the start of care or recertification period

Process:

  1. Obtain verbal certification from the appropriate physician
  2. Document the verbal certification in the patient’s medical record
  3. Follow up to obtain written certification as soon as possible

Important Notes:

  • Verbal certification must be obtained within the same 2-day timeframe as written certification
  • The written certification must be on file before submitting a claim to Medicare

Face-to-Face Visit Requirements

Face-to-face (F2F) visits are required for recertifications after the first 180 days of hospice care. Here are the key points:

Timing:

  • Must occur no more than 30 calendar days before the start of the third benefit period and each subsequent benefit period

Who Can Conduct:

Documentation Requirements:

  1. Attestation that the F2F encounter occurred
  2. Date of the encounter
  3. Signature of the physician or nurse practitioner who conducted the visit
  4. Composition of a brief narrative describing how the clinical findings support continued hospice care

Best Practices:

  • Schedule F2F visits well in advance to ensure compliance
  • Use a checklist to ensure all required elements are documented
  • Coordinate with the interdisciplinary team to gather relevant clinical information

Summary Table: Recertification Requirements

RequirementTimingWho Can CompleteKey Components
Written RecertificationUp to 15 days before the next benefit periodMedical Director or Physician Member of IDGPrognosis statement, narrative, signature
Verbal CertificationWithin two days of the start of care/recertificationAppropriate PhysicianDocumented in the medical record, followed by a written certification
Face-to-Face VisitWithin 30 days before 3rd benefit period and subsequent periodsHospice Physician or Nurse PractitionerAttestation, date, signature, narrative

Remember, the recertification process is not just about compliance—it’s about ensuring that our patients continue to receive the compassionate, comprehensive care they need. By following these guidelines and best practices, we can maintain the highest standards of care while meeting regulatory requirements. Please get in touch with your supervisors or compliance team if you have any questions or need support with the recertification process. Together, we can ensure that our patients receive the best possible care throughout their hospice journey.

Documentation and Record-Keeping

Proper documentation and record-keeping are essential for providing high-quality hospice care and ensuring compliance with regulatory requirements. Let’s explore the key aspects of this critical process.

Clinical Records and Patient Assessments

Maintaining accurate and comprehensive clinical records is crucial for the continuity of care and regulatory compliance. Here are the key components:

Essential Elements of Clinical Records:

  • Patient demographics and contact information
  • Physician certification and recertification documents
  • Initial and comprehensive assessments
  • Plan of care and updates
  • Medication administration records
  • Visit notes from all disciplines
  • Interdisciplinary team meeting notes

Best Practices for Clinical Documentation:

  1. Use clear, concise language
  2. Document in real-time or as soon as possible after patient interactions
  3. Include objective observations and subjective patient reports
  4. Record all interventions and their outcomes
  5. Note any changes in the patient’s condition or care plan

Patient Assessments:

  • Initial Assessment: Must be completed within 48 hours of the start of care
  • Comprehensive Assessment: Required within five calendar days of the start of care
  • Update Assessments: Conducted as needed, based on the patient’s condition

Documentation Tips for Medical Necessity:

  • Clearly describe why the patient is considered terminally ill
  • Document a specific decline in clinical status over time
  • Include detailed descriptions of symptoms and their management
  • Record any secondary conditions or comorbidities affecting the prognosis

Hospice Quality Reporting Program (HQRP) Requirements

The HQRP is designed to promote the delivery of high-quality hospice care. Understanding and meeting these requirements is essential for hospice providers.

Key Components of HQRP:

  1. Hospice Item Set (HIS): Standardized set of items for data collection
  2. Hospice Consumer Assessment of Healthcare Providers and Systems (CAHPS®) Survey: Measures patient and family experiences
  3. Hospice Visits in Last Days of Life (HVLDL) Measure: Assesses hospice staff visits in the final days of life

Reporting Deadlines:

RequirementSubmission Deadline
HIS-Admission RecordWithin 30 days of admission
HIS-Discharge RecordWithin 30 days of discharge
CAHPS® SurveyOngoing throughout the year

Best Practices for HQRP Compliance:

  • Implement a robust quality assurance program
  • Provide regular staff training on HQRP requirements
  • Use electronic health records to streamline data collection and reporting
  • Regularly review and analyze HQRP data to identify areas for improvement

Consequences of Non-Compliance:

  • Potential 2% reduction in Annual Payment Update (APU)
  • Public reporting of hospice performance on the Care Compare website

Remember, accurate documentation and adherence to HQRP requirements not only ensure regulatory compliance but also contribute to better patient care. By maintaining comprehensive clinical records, conducting thorough assessments, and meeting HQRP standards, we demonstrate our commitment to providing high-quality, compassionate hospice care. As hospice professionals, your dedication to these practices is invaluable. Don’t hesitate to contact your supervisors or quality improvement team if you have any questions or need support in implementing these requirements. Together, we can ensure that our documentation and reporting practices support the best possible outcomes for our patients and their families.

Billing and Compliance Considerations

As hospice professionals, understanding billing and compliance requirements is crucial for ensuring proper reimbursement and maintaining regulatory adherence. Let’s explore key aspects of this critical area.

Timely Submission of Notices of Election (NOE)

The Notice of Election (NOE) is a critical document that informs Medicare of a beneficiary’s choice to receive hospice care. Timely submission is essential for proper billing and reimbursement.

Key Points for NOE Submission:

  • Must be submitted within five calendar days after the date
  • Failure to submit within this timeframe can result in payment delays or denials

Best Practices for NOE Submission:

  1. Implement a robust system for tracking admission dates and NOE submissions
  2. Train staff on the importance of timely NOE submission
  3. Regularly audit NOE submission processes to identify and address any issues
  4. Utilize electronic submission methods when possible to expedite the process

Exception Scenarios:

In some cases, late NOE submissions may be accepted without penalty. Common exceptions include:

  • Natural disasters or other emergencies
  • CMS or Medicare Administrative Contractor (MAC) system issues
  • Delays in receiving beneficiary information from another provider

When submitting a late NOE due to an exception, explain the circumstances causing the delay.

Consequences of Late or Incomplete Documentation

Proper documentation is the foundation of compliant hospice billing. Late or incomplete documentation can have severe consequences for your organization.

Potential Consequences:

  • Delayed or denied payments
  • Increased scrutiny from auditors
  • Potential fraud investigations
  • Damage to the hospice’s reputation

Common Documentation Issues:

  1. Missing or incomplete physician certifications
  2. Late submission of NOEs
  3. Inadequate documentation of medical necessity
  4. Incomplete or inaccurate plan of care

Best Practices for Documentation:

  • Implement point-of-care documentation systems to ensure real-time, accurate record-keeping
  • Conduct regular internal audits to identify and address documentation gaps
  • Provide ongoing training for staff on documentation requirements
  • Use checklists and templates to ensure all required elements are included

Addressing Late NOE Submissions:

If you must submit a claim for an untimely NOE, follow these steps:

  1. Submit the NOE as soon as the error is identified
  2. Bill the claim with the appropriate Patient Status Code
  3. Report occurrence span code 77 with the from/through dates of the hospice election
  4. Include remarks explaining the reason for the late NOE
ScenarioAction RequiredPotential Consequence
Timely NOE SubmissionSubmit ASAP, including an explanationProper reimbursement
Late NOE SubmissionSubmit ASAP, including an explanationPayment reduction for days before NOE
Missing DocumentationComplete and submit as soon as possibleDelayed payment, potential audit

Remember, maintaining accurate and timely documentation is not just about compliance – it’s about ensuring that our patients receive the best possible care and that our organizations can continue to provide essential . We demonstrate our commitment to regulatory compliance and high-quality patient care by prioritizing proper documentation and timely submissions. If you encounter challenges with billing or documentation, don’t hesitate to contact your billing department or compliance officer for guidance. Together, we can navigate these requirements and focus on what matters most: providing compassionate, comprehensive care to our patients and their families.

Special Circumstances and Exceptions

Special circumstances and exceptions in hospice care can impact regulatory requirements and billing processes. Understanding these scenarios helps ensure compliance and proper care delivery. Let’s explore two key areas: Retroactive Medicare Entitlement and Emergency Situations and Regulatory Flexibility.

Retroactive Medicare Entitlement

Retroactive Medicare entitlement occurs when a patient’s Medicare coverage is approved or changed to an earlier date than initially determined. This can affect hospice billing and documentation.

Key Points:

  • Definition: Retroactive Medicare entitlement means a patient’s Medicare coverage is backdated earlier.
  • Impact: This can make previously non-covered services eligible for Medicare reimbursement.

Requirements for Retroactive Entitlement:

  1. Proof of Retroactive Medicare Entitlement: Documentation showing the retroactive approval date.
  2. Certification of Terminal Illness: Must meet the Medicare Benefit Policy Manual, Chapter 9, Section 20.1 criteria.
  3. Hospice Election Statement: Must meet the Medicare Benefit Policy Manual, Chapter 9, Section 20.2.1 criteria.

Steps to Handle Retroactive Entitlement:

  1. Gather Documentation: Obtain proof of retroactive entitlement, certification of terminal illness, and hospice election statement.
  2. Submit Claims: Submit claims for services provided during the retroactive period.
  3. Use Appropriate Modifiers: To indicate an exception request, include the ‘KX’ modifier on the non-covered level of care line.

Best Practices:

  • Timely Documentation: Ensure all required documents are completed and submitted promptly.
  • Clear Communication: Keep open lines of communication with Medicare contractors to address any issues.

Emergency Situations and Regulatory Flexibility

Emergencies like natural disasters or pandemics can disrupt hospice operations. Regulatory flexibility during these times helps ensure continued patient care and compliance.

Types of Emergencies:

  • Natural disasters (e.g., fires, floods, earthquakes)
  • Public health emergencies (e.g., pandemics)
  • System issues beyond the hospice’s control

Regulatory Flexibility Measures:

  1. Extensions and Exemptions:
    • CMS may grant extensions or exemptions for data submission and other requirements.
    • Providers can request these within 90 days of the event.
  2. Waivers:
    • CMS can issue waivers for large-scale emergencies, automatically applying to affected providers.

Requesting Extensions or Exemptions:

  1. Provider-Initiated Requests:
    • Submit a request to CMS with documentation of the extraordinary circumstance.
    • Include proof, such as news articles or photos, and occurrence dates.
  2. CMS-Initiated Waivers:
    • CMS may automatically grant waivers during widespread emergencies.
    • Providers do not need to take action for these waivers.

Documentation for Exception Requests:

RequirementDocumentation NeededSubmission Timeline
Proof of Extraordinary CircumstanceNews articles, photos, datesWithin 90 days of the event
Certification of Terminal IllnessMeets Medicare criteriaAs soon as possible
Hospice Election StatementMeets Medicare criteriaAs soon as possible

Best Practices for Emergency Situations:

  • Proactive Planning: Develop contingency plans for emergencies.
  • Staff Training: Ensure staff are trained on emergency protocols and regulatory flexibility.
  • Regular Updates: Keep up-to-date with CMS communications regarding waivers and extensions.

Hospice providers can ensure continued compliance and high-quality care, even in challenging situations, by understanding and preparing for these special circumstances and exceptions. Contact your compliance team or regulatory resources if you have any questions or need support. Together, we can navigate these complexities and focus on providing compassionate care to our patients and their families.

Best Practices for Maintaining Regulatory Compliance

Maintaining regulatory compliance in hospice care ensures high-quality patient care and avoids legal and financial repercussions. Here are some best practices to help hospice nurses, clinical managers, and billing managers comply.

Implementing Robust Internal Processes

Robust internal processes are the backbone of regulatory compliance. They ensure that all aspects of hospice care are consistently monitored and improved.

Key Steps to Implement Robust Internal Processes:

  1. Develop Comprehensive Policies and Procedures:
    • Create detailed policies and procedures that cover all aspects of hospice care, including patient admission, care delivery, documentation, and billing.
    • Ensure these policies are aligned with federal and state regulations.
  2. Designate a Compliance Officer:
    • Appoint a dedicated compliance officer to oversee compliance activities and address any issues.
    • The compliance officer should have a clear understanding of hospice regulations and be able to communicate effectively with staff.
  3. Conduct Regular Internal Audits:
    • Perform regular audits to ensure that all processes are being followed correctly.
    • Use audit results to identify areas for improvement and implement corrective actions.
  4. Utilize Technology:
    • Implement healthcare compliance software to streamline documentation, conduct audits, and monitor real-time compliance performance.
    • Use electronic health records (EHR) to ensure accurate and timely documentation.
  5. Establish a Quality Assurance and Performance Improvement (QAPI) Program:
    • Develop a QAPI program to continuously monitor and improve the quality of care.
    • Identify and prioritize performance improvement activities based on data analysis and patient needs.

Example of an Internal Audit Checklist:

Audit AreaKey Points to CheckFrequency
Patient AdmissionProper documentation, timely NOE submissionMonthly
Care DeliveryCompliance with care plans, accurate documentationBi-weekly
BillingAccurate coding, timely claim submissionMonthly
Staff TrainingCompletion of required training, competency assessmentsQuarterly

Staff Training and Education

Effective staff training and education are crucial for maintaining compliance and ensuring high-quality patient care. Here are some strategies to enhance staff training and education.

Importance of Staff Training:

  • Reinforces knowledge and skills needed to provide high-quality care
  • Improves patient outcomes and satisfaction
  • Boosts staff morale and job satisfaction
  • Enhances regulatory compliance and survey outcomes

Key Areas for Staff Training:

  1. and Clinical Competency:
    • Educate staff on managing schedules, handling late admissions, and solving acute patient situations.
    • Conduct real patient case reviews and ride-along visits to reinforce skills.
  2. Communication and Interpersonal Skills:
    • Train staff on responding to patient and family complaints and resolving issues effectively.
    • Review surveys and complaints to identify areas for improvement.
  3. Cultural Competence and Ethical Issues:
    • Prepare staff to handle cultural and ethical issues with sensitivity and respect.
    • Provide training on delivering unbiased support and education.
  4. Multidisciplinary Roles:
    • Educate staff on the roles of different disciplines in managing patient care.
    • Maximize education opportunities during interdisciplinary team (IDT) meetings.
  5. Compliance and Rationale:
    • Provide in-depth training on hospice-specific compliance requirements.
    • Explain the rationale behind compliance to help staff understand its importance.

Best Practices for Staff Training:

  • Assess Training Needs Regularly:
    • Identify specific knowledge and skills gaps through staff surveys, performance evaluations, and feedback from patients and families.
  • Design Tailored Training Programs:
    • Create training programs that address identified needs using in-service meetings, one-on-one education, and mentorship.
  • Engage and Interactive Training Methods:
    • Use case studies, role-playing exercises, and active learning techniques to make training engaging and effective.
  • Evaluate Training Effectiveness:
    • Assess the impact of training through staff surveys, observations, and feedback from patients and families.
    • Use this feedback to improve future training programs.

Example of a Staff Training Plan:

Training TopicMethodFrequency
Clinical CompetencyIn-services, case reviewsMonthly
Communication SkillsRole-playing, feedback sessionsQuarterly
Cultural CompetenceWorkshops, guest speakersBi-annually
ComplianceOnline modules, in-person sessionsAnnually
Multidisciplinary RolesIDT meetings, cross-trainingOngoing

By implementing robust internal processes and providing comprehensive staff training and education, hospice providers can ensure regulatory compliance and deliver high-quality, compassionate care to patients and their families. If you have any questions or need support, don’t hesitate to contact your compliance team or training coordinator. Together, we can create a supportive and compliant hospice care environment.

Conclusion: Staying Ahead of Regulatory Changes

As hospice nurses, clinical managers, and billing managers, staying ahead of regulatory changes is crucial for maintaining compliance and providing high-quality care. Let’s recap the key points and emphasize the importance of collaboration and vigilance in maintaining compliance.

Recap of Key Points

Throughout our discussion, we have covered several essential aspects of hospice regulatory requirements. Here’s a summary of the key points:

  1. Initial Certification Process:
    • Timing and Documentation: Certification must be completed within two days of admission, with verbal certification allowed temporarily.
    • Physician Narrative and Attestation: A detailed narrative and attestation are required to support the prognosis.
  2. Ongoing Patient Care Requirements:
    • Registered Nurse Case Manager Visits: Must occur at least every 14 days to assess and document patient needs.
    • Plan of Care Updates and Interdisciplinary Team Meetings: The plan of care must be updated every 15 days, and regular IDG meetings are held to ensure comprehensive care.
  3. Recertification Process:
    • Medical Director’s Written Recertification: Required every 90 days for the first year, then every 60 days.
    • Verbal Certifications: Used when written certification is delayed, but written certification must follow.
    • Face-to-Face Visit Requirements: 30 days before the third benefit period and each subsequent period.
  4. Documentation and Record-Keeping:
    • Clinical Records and Patient Assessments: Accurate and timely documentation is essential for compliance and quality care.
    • Hospice Quality Reporting Program (HQRP) Requirements: Regular reporting and adherence to HQRP standards are necessary for maintaining compliance.
  5. Billing and Compliance Considerations:
    • Timely Submission of Notices of Election (NOE): To avoid payment delays, NOEs must be submitted within five calendar days of admission.
    • Consequences of Late or Incomplete Documentation: This can result in denied payments, audits, and potential legal issues.
  6. Special Circumstances and Exceptions:
    • Retroactive Medicare Entitlement: Requires proper documentation and timely submission of claims.
    • Emergency Situations and Regulatory Flexibility: CMS may grant extensions or waivers during emergencies, but proper documentation is still required.

Collaboration and Staying Vigilant

Maintaining compliance is a team effort that requires constant vigilance and collaboration. Here are some best practices to help your team stay ahead of regulatory changes:

1. Foster a Culture of Compliance:

  • Encourage open communication about compliance issues and concerns.
  • Recognize and reward staff for their efforts in maintaining compliance.

2. Stay Informed:

  • Regularly review updates from CMS and other regulatory bodies.
  • Subscribe to newsletters and alerts from organizations like NHPCO and CMS.

3. Conduct Regular Training:

  • Provide ongoing education on regulatory requirements and best practices.
  • Use real-life scenarios and case studies to reinforce learning.

4. Implement Robust Internal Processes:

  • Develop comprehensive policies and procedures.
  • Conduct regular internal audits to identify and address compliance gaps.

5. Utilize Technology:

  • Electronic health records (EHR) and compliance software are used to streamline documentation and reporting.
  • Leverage data analytics to monitor compliance performance and identify areas for improvement.

6. Collaborate Across Disciplines:

  • Hold regular interdisciplinary team (IDT) meetings to discuss patient care and compliance issues.
  • Ensure all team members understand their roles and responsibilities in maintaining compliance.

Summary Table: Best Practices for Compliance

Best PracticeAction StepsBenefits
Foster a Culture of ComplianceEncourage communication, recognize effortsImproved compliance, team morale
Stay InformedReview updates, subscribe to alertsStay current with regulations
Conduct Regular TrainingProvide ongoing education, use case studiesReinforced learning, better compliance
Implement Robust ProcessesDevelop policies, conduct auditsIdentify gaps, ensure consistency
Utilize TechnologyUse EHR and compliance softwareStreamlined processes, accurate documentation
Collaborate Across DisciplinesHold IDT meetings, clarify rolesComprehensive care shared responsibility

By following these best practices, you can ensure that your hospice organization remains compliant with regulatory requirements and continues to provide compassionate, high-quality care to patients and their families. If you have any questions or need support, don’t hesitate to contact your compliance team or regulatory resources. Together, we can navigate the complexities of hospice care and focus on what matters most: providing exceptional care to our patients.

Resources

The Amity Group Summary of Timeline Requirements (Facebook video)

Medicare Benefit Policy Manual: Chapter 9 – Coverage of Hospice Services Under Hospital Insurance (PDF)

Medicare Claims Processing Manual: Chapter 11 – Processing Hospice Claims (PDF)

Code of Federal Regulations; PART 418—Hospice Care

Hospice Certification / Recertification Requirements

State Operations Manual: Appendix M – Guidance to Surveyors: Hospice (PDF)

NHPCO Regulatory & Compliance Center

Hospice Home Care – Frequency of Nurse On-Site Visits to Assess Quality of Care and Services

Hospice Requirements and Best Practices

Hospice Quality Reporting Program

Creating An Effective Hospice Plan of Care (PDF)

Hospice Medical Necessity Tips for Medical Record Review

Hospice Notice of Election (NOE) Exception Examples

Submitting Claims for Untimely Notices of Election (NOEs)

Requesting an Exception for an Untimely NOE

Extension and Exemption Requests

A Guide to Maintaining Hospice Conditions of Participation Compliance

From Theory to Practice: Making QAPI Work for Your Hospice

Staff Training and Development in Hospice Care Is Seriously Underrated

Medicare hospice regulations you need to know

Holistic Nurse: Skills for Excellence book series

Empowering Excellence in Hospice: A Nurse’s Toolkit for Best Practices book series

Tips for Hospice Nurses – Numerous Articles

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