Educate, document, then educate some more
The Health Care Financing Administration (HCFA) plans to expand its five-state survey of hospice Medicare billing practices into a nationwide initiative. Although many hospice administrators throughout the country are confused and more than a little alarmed at the news, there are ways to prepare. Hospice experts reel off a checklist of common sense policies and procedures that hospices should have in place to be prepared.• Know the rules.
"The hospice needs to ensure that it is meeting the conditions of participation both in policy and in the implementation of that policy," says Diane M. Jones, MSW, ACSW, executive director of the Washington, D.C.-based Hospice Association of America. Andrea Dumat, owner of ALD Consultants, a home health and hospice consulting firm in Ophir, OR, recommends that hospice administrators also possess a good understanding of the Health Care Financing Administration’s (HCFA) Medicare fraud and abuse definitions. "People need to understand the definitions of what is fraud and abuse and how the intermediary and HCFA identify problems," she advises.• Make sure appropriate systems are in place.
• Educate employees from day one.
Dumat provides her clients with a pretest in the form of a trivia game for employee orientation that evaluates baseline knowledge. Based on the score, hospice administrators can then pinpoint weak spots and educate new hires accordingly.• Update knowledge on a continual basis.
Periodic refresher classes and inservices make sure that everybody stays current on policies and procedures. "Go back every three months and follow up; you have to readdress issues," Dumat advises. She recommends that not only staff, but management as well attend inservice and refresher courses.
• Document adherence to policies and procedures.
"All the people you talk to, all of the information you gather in terms of deciding whether this person needs hospice needs to be reflected in the record," says Mary Labyak, MSSW, LCSW, executive director of The Hospice of the Florida Suncoast in Largo.• Use checklists to ensure that documentation is complete.
Dumat gives her clients a quality assurance checklist for various non-cancer diagnoses. If at least two boxes in the "yes" column are checked, that shows the hospice made a good faith effort to ensure that patient was appropriate for hospice admission. The more "yeses" the better. Such checklists can be sent along with the patient’s records as documentation, if requested, Dumat says, to show that the hospice was making every effort to follow proper procedure.• Know who your fiscal intermediary representative is.
Understand that it’s part of a process, and decisions are made by people, not a system, and those decisions can be questioned.[For more information on preparing for audits, pretests for new hires and quality assurance checklists, contact Andrea Dumat, owner, ALD Consultants, P O Box 164, Ophir, OR 97464. Telephone: (541) 247-7755. Fax: 541-247-8037.]
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