Eli's Hospice Insider

Published on Sun Nov 21, 2010 PDF

Your reimbursement hinges on these crucial details.

Incomplete or untimely recertifications are among the top reasons the Centers for Medicare & Medicaid Services denies hospice claims. Unfortunately, the new face-to-face encounter (FFE) requirement leaves you with even more rules to remember.

Heather Wilson with Weatherbee Resources and Hospice Education Network offers this checklist to help you jump through all the right hoops when recertifying patients:

1. Within 2 calendar days after a period begins, the hospice must obtain the written and signed recertification. If the hospice can't obtain a written recert, then it must obtain an oral one from the medical director or hospice physician. Remember that you must document that you obtained the recertification orally.

2. The entire recertification should be completed no more than 15 days before the new benefit period starts. "This is to ensure that the determinations are made as close to the benefit period as possible," Wilson says.

3. The face-to-face encounter must happen no more than 30 days before the third (or later) benefit period begins. "That gives a little more lee way for meeting the requirement," although you can't complete everything this far in advance, Wilson notes.

4. The hospice physician or medical director must sign and date the recertification form before you submit the claim. However, "this leeway only applies to the signature on the form, not to the 2-day timeframe for oral certification or the 30-day" window for FFE, Wilson says.

5. Ensure you meet all documentation requirements, including obtaining all necessary dates and signatures, the physician narrative, the attestation statement regarding the narrative, and the attestation statement regarding the FFE.

Remember: Recertification is a "process" -- not an event -- and it has different activities, timeframes, and documentation requirements, Wilson stresses. Post this primer where staff can refer to it as often as they need.