As scrutiny of hospice organizations increase, it’s particularly important for hospices to ensure their certifications and recertifications of terminal illness meet all required elements. In the 2021 Medicare FFS Supplemental Improper Payment Data report of improper payments, the top cause for error was “insufficient documentation of the physician’s certification/recertification”. A few short months from now,…
As scrutiny of hospice organizations increase, it’s particularly important for hospices to ensure their certifications and recertifications of terminal illness meet all required elements. In the 2021 Medicare FFS Supplemental Improper Payment Data report of improper payments, the top cause for error was “insufficient documentation of the physician’s certification/recertification”. A few short months from now, the Office of Inspector General (OIG) will begin a focused audit of hospice eligibility of Medicare beneficiaries—particularly those referred from the community. Hospices should ensure their certifications and recertifications contain all the required documentation. In particular, the hospice certification must be based on the physician’s or medical director’s judgment which is supported by clinical information. The physician is to provide a brief narrative of clinical findings and an attestation confirming the written report is based upon a review of the patient’s medical record or, if applicable, the examination of the patient. The physician’s signature and date must immediately follow the narrative. Clinical information and other documentation supporting the medical prognosis must accompany the certification and maintained in the patient’s medical record. Now is the time to examine your patients’ eligibility to ensure your records can withstand medical review.
