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Hospices Fear Financial Implications Under Expanded Diagnosis Code Reporting

CMS:  ‘Hospices are required to provide virtually all the care that is needed ... at the end of life.’

Medicare won’t be returning hospice claims that list only one diagnosis code, but providers can bet those claims will come under increased scrutiny.

Despite instructions from the Centers for Medicare & Medicaid Services in last year’s payment rule, hospices are still reluctant to list more than one code on claims. A large 72 percent of hospices continue to report only one diagnosis code on hospice claims, CMS notes in the proposed hospice payment rule for 2014 published in the May 10 Federal Register. That’s down from 77 percent before last year’s notice.

Part of the reason hospices aren’t reporting a long list of diagnosis codes for every patient is that they don’t want to get stuck footing the bill for services and items that aren’t related to the terminal illness. Multiple callers in CMS’s May 8 Open Door Forum for home care providers asked about hospices’ coverage and financial responsibilities related to the additional diagnoses listed on the claim.

“You’re responsible for the diagnosis — the terminal illness diagnosis and all related conditions,” a CMS official said.

“When we talk about hospice covering terminal illness and related conditions, we view that very holistically,” insisted CMS’s Kate Lucas in the forum.

Lucas cited CMS’s 1983 hospice final rule establishing the program: “The unique physical conditions of each terminally ill individual makes it necessary for decisions about what’s related and unrelated being made on a case by case basis, but it’s our general view that hospices are required to provide virtually all the care that is needed by terminally ill patients at the end of life. The conditions that are not normally clinically related become clinically related because the body is shutting down and those systems are interrelated. When somebody is truly at end of life, these conditions are related and we would expect that the hospice should be covering them and providing the care for those.”

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