In the News: CMS Updates

Recently CMS updated its website’s Hospice Questions and Answers section. There were revisions and updates to previously listed Questions and Answers, and the following highlights examples of questions revised or newly listed.

Facility Specific Care Site Coding

  • Skilled Nursing Facility versus Unskilled Nursing Facility Service Codes

  • When a hospice patient resides in a dually-certified skilled and unskilled nursing facility, the hospice should report the code that most appropriately reflects the level of care [skilled or unskilled] that the facility staff is providing to the hospice patient.  Specifically, Q5003 is reported for unskilled care services and Q5004 when skilled care services are being provided by facility staff to the patient.  It is important that hospice providers keep in mind that General Inpatient [GIP] hospice care patients must be receiving, at a minimum, skilled nursing care from facility staff in order that the hospice patients meet the CMS hospice regulations for this hospice care level.

  • Hospice Residential versus Hospice Inpatient Facility Care Codes

    At the current time routine home care [RHC] and continuous home care (CHC) levels of care for patients residing in a hospice inpatient facility should be appropriately coded as Q5006.  Both of these care levels for patients residing in a hospice residential facility would be coded appropriately as Q5009.  However, it is important to note that CMS is considering a revision to these codes in the future, so providers should regularly access the CMS website https://questions.cms.hhs.gov/app/answers/detail/a_id/10005.

Visit Recording

 

  • Recording Visits
  • Routine home care (RHC) and continuous home care (CHC) patients residing in a facility have their visits counted the same as if they were residing in their own home.  However, any visits, which would normally be considered part of the facility’s room and board services, are not to be counted and reported on hospice Medicare claims.  For example, delivering meals, changing bed linens and housekeeping tasks would be considered room and board services, which are normally provided by the residential facility and would not be reported on hospice Medicare claims.  In addition, hospice providers should not count each time providers enters the patient’s room, but rather should ask themselves the question, “Can these tasks be normally provided during only one in-home visit?”  If the answer is yes, then the visit should only be counted as a single visit.

  • Multiple Provider Visits
  • In the case when more than one health care provider is providing care simultaneously, each provider visit can be counted, but only if the visits are required for the palliation and management of the terminal illness and related conditions as described in the patient's plan of care.  These cannot be counted when the listing of these visits is for the objective of increasing the overall number of visits or in the case where two providers are needed, for example, to turn a patient or to educate one or the other providers present.

Summary

As hospice providers are aware, they must create a system that accurately counts all clinical staff [such as hospice nurse, home health/hospice aide, social worker, physical or occupational therapist, speech language pathologist or physician] interactions with patients.  These are usually considered to be in-person visits, except for specific types of phone calls, which are made by a social worker, which can also be counted.  Hospices are continually cautioned to use sound clinical judgment in counting visits and accurately totaling care time.

Reference:  http://www.cms.gov/center/hospice.asp

   
 
Glatfelter HCCIS is a division of the Glatfelter Insurance Group
© 2010 Glatfelter Insurance Group