Medicare Compliance & Reimbursement

Hospice docs can furnish consultation under new HCPCS code.

Starting in January, hospices will have one more way to secure reimbursement for their services from the Medicare program.
 
The Centers for Medicare & Medicaid Services has established HCPCS code G0337, which will allow hospice medical directors or other hospice-employed physicians to furnish pre-election hospice evaluation and counseling services.
 
"Many hospices may be very happy to take advantage of the provision for a hospice consultation visit," predicts clinical consultant Judy Adams with LarsonAllen Health Care Group based in Charlotte, NC. Hospices will bill the service to their regional home health intermediary.
 
CMS will reimburse the G code at $54.57, according to the final physician fee schedule published in the Nov. 15 Federal Register. But parties who commented on the proposed schedule argued that payment "does not accurately reflect the complexity associated with the hospice consultation," CMS says in the final rule.
 
Commenters also wanted payment to depend on the length and intensity of the consultation.
 
CMS says its hands are tied on these issues by the specifics in the Medicare Modernization Act, which enacted the new service.
 
While the payment isn't enough to compensate physicians adequately, "many hospice medical directors who have a strong commitment to hospice will still welcome this change as a movement in the right direction," Adams expects.
 
The new service comes with restrictions and requirements, CMS noted in its Nov. 9 Open Door Forum for home care providers. Hospices should note these specifics:

  Terminal illness. The service is only for patients who meet the six-month prognosis for terminal illness. Unlike with a hospice election, the physician doesn't have to certify the illness and prognosis, a CMS official noted in the forum.

  Employed physicians only. Only physicians - not nurse practitioners, social workers or other hospice staff - can furnish the service. And the service is restricted to medical directors or employed physicians only, excluding physicians the hospice may contract with.
 
  Referrals. Patients may refer themselves for this service; CMS does not require a physician's referral. But if a beneficiary self-refers and doesn't meet the six-month prognosis, the hospice won't be eligible for payment, the CMS official said in response to questions.
 
  Documentation. If the patient self-refers, the hospice should keep a medical record on the patient documenting the service. If another physician refers the patient, the hospice physician should forward a note to be included in the patient's medical record under the referring physician.
 
More detailed billing and other instructions will be forthcoming in Medicare correspondence soon, a CMS official said in the forum.