Expect this issue to catch auditors' attention.
The problem: Although hospices are responsible for paying for pain and other medications related to the hospice resident's terminal illness, it's not uncommon for the facility pharmacy to fill the medication order, says attorney Paula Sanders, partner with Post & Schell in Harrisburg, Pa. And "if the documentation isn't clear, the pharmacy may bill the wrong party for the medication."
"In some cases, hospice may be paying the nursing home, but if bookkeeping doesn't track it, there could be double billing on the nursing home's part," adds attorney Robert W. Markette Jr., CHC, with Gilliland & Markette LLP in Indianapolis.
Solution: Nursing facilities and hospices should have audits in place to make sure improper billing for medications doesn't happen inadvertently,counsels Sanders. "Most facilities have become really good at checking for consolidated billing issues," she notes, "but they don't necessarily have hospice pharmaceutical billing on their radar screen." The issue is similar to consolidated billing,however, she adds. You have to make sure "the right entity is being billed and paying for the right services."
Watch out: The hospice has to be careful about helping the nursing home with its billing, says Markette,noting that the HHS Office of Inspector General worries that hospices are going to offer nursing homes inducement for services. "But the hospice and nursing home can certainly compare notes to make sure the nursing home isn't billing pharmaceuticals to Medicare Part B, D, or Medicaid when the hospice should be covering the pharmaceuticals."