Home Health & Hospice Week

Outdated forms put you at risk.

With so much on your plate these days, you may be letting some basic forms requirements fall by the wayside. Now's the time to get your forms back on track.

HHH Medicare Administrative Contractor Palmetto GBA recently announced hospice claims denial rates of 47 percent and 45 percent in a recent Routine Home Care probe (see story, p. 297).

Two of the top denial reasons, "Physician Narrative Statement Not Present or Not Valid" and "No Valid Election Statement Submitted" frequently boil down to "forms issues," judges Carrie Cooley, COO with Weatherbee Resources in Hyannis, Massachusetts. Hospices often neglect to update their election statement or physician narrative forms when new requirements are issued, resulting in technical claims denials.

For example: Palmetto notes that "the narrative shall include a statement under the physician signature attesting that by signing, the physician confirms that he/she composed the narrative based on his/her review of the patient's medical record or, if applicable his or her examination of the patient." "Composed" is the key word in that requirement, Cooley stresses. The form a hospice uses may simply leave out that statement under the signature, opening up a claim to a denial.

Another example: Palmetto points out that an election statement must include "the individual's or representative's acknowledgement that he or she has been given a full understanding of the palliative rather than curative nature of hospice care, as it relates to the individual's terminal illness." Some hospices' election statement forms don't include that palliative-versus-curative care language, Cooley reports.

One of the biggest election statement pitfalls hospices encounter is neglecting to put the attending physician designation on their forms, Cooley says.

MAC CGS notes on its Hospice Election Requirements webpage that the election statement must include "the patient's or representative's designated attending physician (if they have one). Include enough detail to clearly identify the attending physician. This may include, but is not limited to, the physician's full name, office address, or National Provider Identifier (NPI)." (For CGS's list of election statement requirements, see box, this page.)

Heed Cooley's advice to avoid denials like the ones Palmetto made in its latest probe:

1. Review forms at least annually. Hospices should have a formal process to review their documents for compliance at least once a year, Cooley advises. A good time is after the annual payment update rule is finalized, so you can incorporate any changes from the rule.

2. Destroy outdated forms. Don't be tempted to use up your old forms before switching over to updated ones, or to ignore the old forms floating around.

Avoid this scenario: A common opportunity for noncompliance is when one of your nurses who works only on the weekend pulls an old form out of the packet in her car because that's all she has on hand, Cooley gives as an example. Make sure you round up all the old admission packets and other paperwork and destroy them when you replace them with a new version.

3. Implement a pre-billing audit. Hospices should have an effective process in place to ensure the validity of all their forms, as well as other requirements, before billing, Cooley emphasizes. That way hospices can fix any problems before it's too late.

The old adage "an ounce of prevention is worth a pound of cure" definitely applies to hospice billing and the burden of implementing a pre-billing audit, she says. "A solid pre-billing verification process prevents about 95 percent" of the types of errors seen under these top denial reasons, Cooley tells Eli.