Home Health & Hospice Week

Sidestep the most common pitfall from a recent OIG review.

Don’t be surprised to see increased scrutiny of Notice of Election statements in the wake of a report covering the topic from the HHS Office of Inspector General.

In a claim review of 2012 GIP claims, the OIG founds problems with about one-third of NOEs (see related story, p. 273).

Face it: “The hospice industry must wake up to the fact that ever-increasing scrutiny will not … blow over, so that we can all go back to ‘touchyfeely’ hospice care without accurate, thorough documentation to support payment for hospices’ medically necessary services,” says consultant Beth Noyce with Noyce Consulting in Salt Lake City.

“Once the OIG and CMS find problems within a program, the issue never drops from their sights,” she laments.

Bottom line: “Get used to it,” Noyce advises in report analysis posted to her blog.

To make sure your NOEs are toeing the regulatory line, the National Association for Home Care & Hospice and affiliated Hospice Association of America advises agencies to make sure their election statements:

• specify that the patient is electing the Medicare hospice benefit. This was the OIG’s biggest problem in the review.
• explain the coverage waived when electing hospice;
• spell out palliative versus curative care;
• detail revocation versus transfer versus discharge.

Tip: For palliative versus curative care and revocation/transfer/benefit information, your election statement can “specifically reference where this explanation can be found in materials presented to the patient prior to election,” NAHC offers.