Home Health & Hospice Week

 Documenting your medical director's service is a must.

Your hospice medical director arrangements could be your compliance Achilles heel if you're not careful.
 
In its newest instructions on using the new hospice pre-election evaluation and counseling service (G0337), the Centers for Medicare & Medicaid Services warns against kickback violations with physicians who can refer to your hospice (see story, p. 108).
 
Experts offer these four tips to stay on the right side of the anti-kickback statute with your medical director:

1. Have a detailed contract. Your contract with your medical director should spell out all the services he will perform for you, advises attorney Connie Raffa with Arent Fox in New York City.
 
2. Document the services. Your arrangement with your medical director "can't just look good on paper," Raffa urges. Make sure your director is really performing the services your contract sets out.
 
Documenting the services is a must, advises John Mahoney, principal of the Summit Business Group in Penfield, NJ.
 
3. Pay fair market value. "Reflect reasonable market rates" in your compensation to the physician, counsels Mahoney, former president of the National Hospice Organization. That means you'll have to determine fair market value for your area, Raffa notes.
 
4. Don't overpay for G0337. If you want to pay your part-time employed physician extra for furnishing pre-election evals, don't pay her too much, Raffa warns. She suggests passing along the G0337 payment rate, minus a fair-market-value amount for your administrative processing - and spelling out those specific amounts in the contract with the director.