Eli's Hospice Insider

Published on Wed Dec 28, 2016 PDF

What’s your next move?

If you can’t decide exactly what to do about Medicare’s new model hospice election statement, you’re not alone.

Hospices can expect scrutiny on the claims and survey fronts on this requirement, given the HHS Office of Inspector General and Centers for Medicare & Medicaid Services focus on the area, predicts consultant Kurt Kazanowski with Hospice Advisors in Plymouth, Mich.

In light of the new model form (see story, p. 1), consider these courses of action:

Option #1: Adopt the form. Implementing CMS’s recently released “Medicare Hospice Notice of Election Statement” can help ensure regulatory compliance, which is a big deal at survey time, Kazanowski tells Eli. Form adoption is “a safe call, and probably a wise call.”

Option #2: Continue with your own form. Many hospice agencies, particularly those that are larger with more resources, already use election statements that contain all the required elements present in CMS’s new form, Kazanowski observes. Switching to a new election statement format could cause unnecessary costs ranging from printing new forms to staff training and education.

Plus, “CMS has included some items in the form that are not explicitly required (such as the witness signature) and hospices may have other items that they want to include in their forms,” points out Theresa Forster with the National Association for Home Care & Hospice. In its September report on election statement problems, the OIG noted favorable elements many hospices include on the statements include cost information such as drug copays, transfer policies, and a 24-hour phone number.

Option #3: Modify your form. Given that the model form is still a draft with some kinks to work out, your best strategy might be a compromise between wholesale adoption and ignoring the new form. “We don’t necessarily recommend that hospices use this form in its entirety,” Forster allows. “But this is a good model to use to double check to ensure that the electionstatement a hospice is using contains all of the required elements and will pass muster with the MACs or other reviewers.”

Tip: To get more input on what your election statement should look like and learn more about industry best practices among your peers, Kazanowski recommends contacting your state association or accrediting body, who are already “on your team.”

Whichever option you choose, you should count on spending some time and resources on training your staff for compliance with this hot button topic, Kazanowski advises.