Hospice Election Statements Lack Required Information or Have Other Vulnerabilities

On a weekly basis the Centers for Medicare & Medicaid Services (CMS) issues MLN Connects (Connects), providing official CMS News from the Medicare Learning Network.  While most postings to Connects represent new information that has recently been issued, an item in the October 5 Connects under Provider Compliance is labeled as a REMINDER notice to hospice providers.  The full text of the item is provided below.  The National Association for Home Care & Hospice (NAHC) cautions hospices that they may want to review the materials cited by CMS to ensure that they are in compliance with requirements, including informational items that must be included on the hospice election statement and that hospice General Inpatient (GIP) stays are ordered by a physician and that documentation in the patient record provides justification for coverage.  Following is the text of the notice:

After a stratified random sample review of hospice election statements and certifications of terminal illness, the Office of the Inspector General (OIG) reports that more than one-third of hospice General Inpatient (GIP) stays lack required information or had other vulnerabilities.

  • Hospice election statements did not always mention – as required – that the beneficiary was waiving coverage of certain Medicare services by electing hospice care or that hospice care is palliative rather than curative
  • In 14 percent of GIP stays, the physician did not meet requirements when certifying that the beneficiary was terminally ill and appeared to have limited involvement in determining that the beneficiary’s condition was appropriate for hospice care

Hospices should improve their election statements and ensure that physicians meet requirements when certifying beneficiaries for hospice care. Resources: