Specificity Scores Over Length When It Comes To Hospice Documentation

By Author: Angela MArtin
Total Articles: 206
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Worried about how physicians should write their attestations of hospice patients terminal illness? Hospices don't get much guidance from a recent CMS Q&A on the matter.


When you check out the new CMS requirement that took effect on October 1 last year, you'll find out that they have not mandated that specific language be included in the physician's attestation.


CMS lays down that any language under the physician's signature which attests that by signing, the physician confirms that she composed the narrative based on her review of the patient's medical record or, if applicable, her examination of the patient meets the attestation regulatory requirement.


The physician narrative is not tricky, but it can be hard to get physician paperwork. As such, you need to have a system in place where you track down the doctor to get the dated and signed certification paper work before you bill.


In fact, some home health agencies send clerks to wait in the doctor's office and ...
... actually find that it saves money in the long run. Instead, if you are caught up in a fraud edit, you would need to pull records, make copies and scans, pay for an attorney, and conduct an appeals process. All this can add up to great expenditure.


Performing internal compliance audits, with the help of a qualified attorney can be cheaper in the long run. Anything found would be covered under attorney client privilege and you can fix what you found before it lands you in trouble with the government.


The narrative can be short, but by simply stating ‘based on the patient's diagnosis, I certify that this patient has a prognosis of six months or less' will do the trick for you.


Surveyors can cite failure to have this documentation on file. If you miss a record, it can bring unwanted attention. The narrative must be specific and unique to the patient and should not contain check boxes or boilerplate text.

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