This week's You Asked..We Answered question asks: "What do you do in a case where the hospice recertification is not signed until five days after the benefit period begins? For example, if the recertification date is November 20 and physician’s narrative is dated November 25, how should a hospice proceed? We do obtain the verbal certification for each benefit period within two days after the start of the benefit period."
What do you do in a case where the hospice recertification is not signed until five days after the benefit period begins? For example, if the recertification date is November 20 and physician’s narrative is dated November 25, how should a hospice proceed? We do obtain the verbal certification for each benefit period within two days after the start of the benefit period.
LeadingAge Ohio reached out to Palmetto GBA to determine if it is acceptable to obtain a verbal certification for subsequent benefit periods. The Palmetto representative said a verbal certification is applicable for all certification periods, so as long as you have a verbal certification within two days after the benefit period begins, and a written certification prior to billing, you would be compliant with the regulations.
Please see the Hospice Benefit Manual excerpt from Chapter 9, as well as information on the CGS Medicare website, below.
20.1 - Timing and Content of Certification
(Rev. 188, Issued: 05-01-14; Effective: 08-04-14; Implementation: 08-04-14)
For the first 90-day period of hospice coverage, the hospice must obtain, no later than 2 calendar days after hospice care is initiated, (that is, by the end of the third day), oral or written certification of the terminal illness by the medical director of the hospice or the physician member of the hospice IDG, and the individual’s attending physician if the individual has an attending physician.
The attending physician is a doctor of medicine or osteopathy who is legally authorized to practice medicine or surgery by the state in which he or she performs that function, or a nurse practitioner, and is identified by the individual, at the time he or she elects to receive hospice care, as having the most significant role in the determination and delivery of the individual’s medical care. A nurse practitioner is defined as a registered nurse who performs such services as legally authorized to perform (in the state in which the services are performed) in accordance with State law (or State regulatory mechanism provided by State law) and who meets training, education, and experience requirements described in 42 CFR 410.75.
Note that a rural health clinic or federally qualified healthcare clinic (FQHC) physician can be the patient’s attending physician but may only bill for services as a physician under regular Part B rules. These services would not be considered rural health clinic or FQHC services or claims (e.g., the physicians do not bill under the rural health clinic provider number but they bill under their own provider number).
Initial certifications may be completed up to 15 days before hospice care is elected. Payment normally begins with the effective date of election, which is the same as the admission date. If the physician forgets to date the certification, a notarized statement or some other acceptable documentation can be obtained to verify when the certification was obtained.
For the subsequent periods, recertifications may be completed up to 15 days before the next benefit period begins. For subsequent periods, the hospice must obtain, no later than 2 calendar days after the first day of each period, a written certification statement from the medical director of the hospice or the physician member of the hospice’s IDG. If the hospice cannot obtain written certification within 2 calendar days, it must obtain oral certification within 2 calendar days. When making an oral certification, the certifying physician(s) should state that the patient is terminally ill, with a prognosis of 6 months or less. Because oral certifications are an interim step sometimes needed while all the necessary documentation for the written certification is gathered, it is not necessary for the physician to sign the oral certification. Hospice staff must make an appropriate entry in the patient's medical record as soon as they receive an oral certification.
The following is an excerpt from the CGS Medicare website:
Timeframe for Certification/Recertification
The hospice must obtain verbal or written certification of the terminal illness, 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 within 2 calendar days, verbal certification must be obtained. The hospice must determine who may accept verbal certification from a physician in compliance with state and local law regulations.
In addition, the hospice must ensure the written certification/recertification is signed and dated prior to billing Medicare, or their claim(s) may be denied.