Home Health & Hospice Week

If you miss getting a hospice patient's faceto-face encounter visit in the 30 days before her third benefit period starts, more than reimbursement is at stake. You'll need to do a Medicare discharge and readmission.

So said the Centers for Medicare & Medicaid Services in a March 28 session at the National Association for Home Care & Hospice's annual March on Washington conference. A recent question-and-answer set issued by CMS backs up this new instruction.

Hospices have to terminate a Medicare episode when they don't secure the F2F in time, CMS's Lori Anderson explained. Then they can start back up when the F2F is completed.

That means the hospice will have to do a full readmission, Anderson said in response to a question from an attendee. "It would be a break in service," she said. "There's no wiggle room here."

Discharging the patient from Medicare doesn't mean you have to discharge her altogether, though. "The hospice may continue to serve the patient under hospice care, but in doing so assumes all financial responsibility for that care," CMS says in a new Q&A.

Tip: Hospices can't bill using the occurrence span code 77 to reflect non-covered days, CMS says in another Q&A. Patients without valid F2F visits must be discharged.

It is OK, however, for the attestation to occur afterward. Like other certification paperwork, the attestation just must be completed before billing, Anderson noted at the conference.

CMS is giving hospices plenty of leeway in the definition of "exceptional circumstances" that will allow the F2F visit to occur two days after the third benefit period starts, instead of 30 days before, Anderson noted.

CMS does give two examples in the new Q&As: "If the patient is an emergency weekend admission, it may be impossible for a hospice physician or NP to see the patient prior to admission. Or, if CMS data systems are unavailable, the hospice may be unaware that the patient is in the third benefit period."

Whatever the exceptional circumstances are, the hospice must document them, Anderson said in the conference.

Plus: "For such documented exceptional cases, if the patient dies within 2 days of admission without a face to face encounter, a face to face encounter can be deemed as complete," CMS says in a new Q&A.

Hospices need to be following the F2F requirement now, Anderson emphasized. "It's the law, so the expectation is that people are complying with the provision," she told attendees.