Home Health & Hospice Week

Here are steps you can take now to head off RAC audit-related problems down the road:

• Strengthen documentation. "Has the hospice adequately and accurately determined and documented what services provided to the patient were and were not related to the terminal illness?" asks consultant Heather Wilson with Weatherbee Resources in Hyannis, Mass. Make sure your documentation makes this clear to avoid being on the hook for gray-area items and services.

Hospices must "proactively set up good clinical systems to consistently determine what is truly unrelated to the terminal illness," counsels attorney Mary Michal with Reinhart Boerner VanDeuren in Madison, Wis. Then make sure the systems and decisions are well documented.

• Encourage good documentation in your partners. In the nursing home patient medication scenario, a representative from your hospice and the home should go through the patients' medications and decide which ones are unrelated to theterminal illness, says attorney Connie Raffa with Arent Fox in New York City. That should be "clearly delineated in the nursing home record," she adds.

• Get specific with diagnoses. A vague diagnosis for your patient can make everything seem related. "If the patient has a diagnosis of failure to thrive or debility unspecified, it is quite difficult, in my opinion, to take the position that there is much covered care that is unrelated," Michal tells Eli.

• Don't boost outside billing. "Hospices must be vigilant in avoiding any encouragement of their vendors to bill outside of the Medicare hospice benefit, unless it is clinically substantiated that the bill is for services, equipment, or supplies that are unrelated to the patient's terminal illness," Michal advises.

For example: "If the patient needs a specialized bed, and the hospice tells its contracted durable medical equipment provider that the need for the bed is unrelated, and to go ahead and bill Medicare directly, it will be critical to clearly substantiate why the need for the bed and the patient's diagnosis are not related," Michal explains.

• Review vendor contracts. Hospices should ensure all their vendor contracts are up to date and accurate, recommends consultant Robin Seidman with Simione Consultants in Westborough, Mass. That includes those for SNFs, assisted living facilities (ALFs), inpatient facilities, DME,pharmacy, and more, Seidman reminds hospices.

"It is also helpful for providers to evaluate their costs per day of vendor items and compare themselves to industry benchmarks," Seidman advises.

• Set up billing liaisons. Billing can get pretty confusing when the patient is in the hospital or nursing home. It's a good idea to designate a billing liaison for these relationships, Raffa suggests-- one for the hospice and one for the other provider (hospital, nursing home, etc.). They can keep billing on the right track and ensure the hospice is paying for the services and items it is responsible for under Medicare rules.