General Inpatient Care Getting It Right. Katie Wehri, CHPC Director of Operations Consulting

Similar documents
Medicare Hospice General Inpatient Level of Care

4/24/17. Today s Presenters. Disclaimer. Nursing Documentation-Supporting Terminal Prognosis

Disclaimer. January 2015 Palmetto GBA - Jurisdiction 11 Medicare Administrative Contractor 2

HOSPICE TARGETED PROBE & EDUCATE Melinda A. Gaboury, COS C Healthcare Provider Solutions, Inc.

General Inpatient Level of Care: Managing Risks

NURSING FACILITIES: FRIENDS OR FOES? Marie C. Berliner Joy & Young, LLP Austin, Texas (512)

Hospice Continuous Home Care LEGACY HOSPICE

National Hospice and Palliative Care OrganizatioN. Facts AND Figures. Hospice Care in America. NHPCO Facts & Figures edition

Using Clinical Criteria for Evaluating Short Stays and Beyond. Georgeann Edford, RN, MBA, CCS-P. The Clinical Face of Medical Necessity

401. Hospice Compliance Management: Lessons Learned from Pre-Claim Review

RESPITE CARE LEGACY HOSPICE

Palliative and Hospice Care In the United States Jean Root, DO

Two Midnight Rule What does it mean for Coders?

Palmetto GBA Hospice Coalition Questions August 7, 2001

The Concerns. Hospice Care in The Nursing Home NHPCO MLC All Rights Reserved 1.

Medicare Hospice Billing 2015 & Beyond!

State of California Health and Human Services Agency Department of Health Care Services

2015 National Training Program. History of Modern Hospice. Hospice Legislative History. Medicare s Coverage of Hospice Services

The Medicare Hospice Benefit. What Does It Mean to You and Your Patients?

Hospice Discharges. Legacy Hospice

Office of Inspector General. Vulnerabilities in the Medicare Hospice Program Affect Quality Care and Program Integrity: An OIG Portfolio

Hospice Care in the Nursing Home: The New Interpretive Guidelines for NF Surveyors

ELIGIBILITY & CERTIFICATION THE CONTINUING SAGA

CGS Administrators, LLC Clinical Hospice Documentation from CGS Missouri Hospice & Palliative Care Assoc. October 3, 2016

Medicare Part A provides a special program for persons needing hospice care.

Overview of Presentation

STATE HOSPICE ORGANIZATION AND PALMETTO GBA COALITION MEETING SUMMARY

Department of Veterans Affairs VHA DIRECTIVE Veterans Health Administration Washington, DC December 7, 2005

LOUISIANA MEDICAID PROGRAM ISSUED: 04/15/12 REPLACED: CHAPTER 24: HOSPICE SECTION 24.3: COVERED SERVICES PAGE(S) 5 COVERED SERVICES

EM Coding Newsletter & Advisory Critical Care Update

Medicare Regulations and Rules Update What Should You Know?

What s Happening in the Nursing Home? Cherry Meier, RN, MSN, NHA Vice President of Public Affairs

08-16 FORM CMS

Hospice and End of Life Care and Services Critical Element Pathway

CMS Initiative to Reduce Avoidable Hospitalizations Among Nursing Facility Residents Phase 2--Payment Model

Your Results for: "NCLEX Review"

CLINICAL CRITERIA FOR UM DECISIONS Skilled Nursing Facilities

4/17/2017 OBJECTIVES FEDERAL REQUIREMENTS. Having the Difficult Conversation: We need to Discharge You from Hospice

Partnering with Hospice: Reducing Skilled Nursing Facility to Hospital Readmissions

Talking to Your Doctor About Hospice Care

HCCA South Central Regional Annual Conference November 21, 2014 Nashville, TN. Post Acute Provider Specific Sections from OIG Work Plans

HOSPICE IN MINNESOTA: A RURAL PROFILE

Organization and administration of services

Long Term Care Hospital Clinical Coverage Policy No: 2A-2 Services (LTCH) Amended Date: October 1, Table of Contents

State Operations Manual. Appendix M - Guidance to Surveyors: Hospice - (Rev. 1, )

CMS CR 6440: Additional Documentation on Hospice Claims Related Q&A s

What do we promise people who are dying and those around them when we tell them about hospice care?

Palmetto GBA Hospice Coalition Questions and Answers

Reference Guide for Hospice Medicaid Services

Payment Reforms to Improve Care for Patients with Serious Illness

Having the Difficult Conversation: We need to Discharge You from Hospice

April 8, 2013 RE: CMS 3267 P. Dear Administrator Tavenner,

Medical Review: Past, Present and Future

Hospice Education Network. PATIENT CARE CoPs: INTERDISCIPLINARY GROUP, CARE PLANNING, AND COORDINATION OF SERVICES - HOW TO PREPARE

New in Current payment risks. Tips & strategies. Revenue Cycle: The Ca$h Connection. CPAs & ADVISORS

FY2018 Hospice Wage Index Final Rule

While receiving hospice care services, non-hospice services may still be covered under other portions of the benefit plan.

Home Health Eligibility Requirements

($ Inpatient Units) Catherine Mitchell VP Finance and CFO Hospice of the East Bay Napa Valley Hospice & Adult Day Services

Providing Hospice Care in a SNF/NF or ICF/IID facility

Chronic Care Management. Sharon A. Shover, CPC, CEMC 2650 Eastpoint Parkway, Suite 300 Louisville, Kentucky

Health Management Policy

Overview of the Hospice Proposed Rule

WHAT IS DOCUMENTATION?

OASIS ITEM ITEM INTENT

Hospice Regulatory & Quality Reporting Update. Summary of FY2019 Hospice Wage Index Final Rule 9/12/2018 TRENDS IN HOSPICE UTILIZATION

Hospice House Network Inpatient Conference

UnitedHealthcare Medicare Readmission Review Program for Medicare Advantage Plans General Clinical Guidelines for Payment Review

CURRENT OIG ENFORCEMENT INITIATIVES: A ROAD MAP FOR HIGH RISK COMPLIANCE AREAS

MLN Matters Number: MM6699 Related Change Request (CR) #: 6699

The Monthly Publication of the National Hospice and Palliative Care Organization

Hospice Care For Dementia and Alzheimers Patients

HH Compare. IMPACT Act. Measure HHVBP

Hospice Clinical Record Review

Review Process. Introduction. InterQual Level of Care Criteria Long-Term Acute Care Criteria

Home Health, Hospice, and Nursing Facility. Indiana Health Coverage Programs DXC Technology October 2017

Initiative to Reduce Avoidable Hospitalizations Among Nursing Facility Residents. Payment Model

Cigna Medical Coverage Policy

Common Questions Asked by Patients Seeking Hospice Care

MEMORANDUM Texas Department of Human Services * Long Term Care/Policy

MEDICARE By Peter G. Pan

Thank you for joining us!

Medicare: This subset aligns with the requirements defined by CMS and is for the review of Medicare and Medicare Advantage beneficiaries

Prior Authorization form for Post-Acute Care Admission and Recertification for SNF,LTAC and Rehab

Using Clinical Criteria for Evaluating Short Stays and Beyond

DEMONSTRATED NEED FOR SKILLED CARE FOR MEDICARE PATIENTS: SKILLED NURSING SERVICES

HOMECARE AND HOSPICE REIMBURSEMENT

2017 FOCUSED ON DOCUMENTATION NECESSITIES & PRE-CLAIM REVIEW

Developing A Discharge Process: Merging Regulation and Patient/Family Satisfaction

(f) Department means the New Hampshire department of health and human services.

MDS Essentials. MDS Essentials: Content. Faculty Disclosures 5/22/2017. Educational Activity Completion

One Chance to Get it Right Simulation Scenario 2 End of Life Care at Home

Individualised End of Life Care Plan for the Last Days or Hours of Life Patient name Hospital number Date of birth

Hospice: Background 1963: 1965: 1968: 1969: 1972: 1974: : 1978:

CMS OASIS Q&As: CATEGORY 2 - COMPREHENSIVE ASSESSMENT

Royal Liverpool Children s NHS Trust Alder Hey Rapid Discharge Pathway for End of Life Care

Medicare Home Health Prospective Payment System (HHPPS) Calendar Year (CY) 2013 Final Rule

Death and Dying. Shelley Westwood, RN, BSN Bullitt Central High School

Partnering with the Care Management Department. Medical Staff and Allied Health Practitioner Orientation

Creating a Culture of Quality and Compliance

Transcription:

General Inpatient Care Getting It Right Katie Wehri, CHPC Director of Operations Consulting Kwehri@healthcareprovidersolutions.com Review Identify Discuss Share Review the CMS regulations for the GIP level of care and the current regulatory environment Identify patient eligibility criteria and expected documentation for the GIP level of care Discuss barriers to the use of GIP Share applicable scenarios for utilizing the GIP level of care Objectives 1

The Concerns ARE PROVIDERS OFFERING THE FULL RANGE OF SERVICES? ARE PROVIDERS INAPPROPRIATELY ADMINISTERING THE BENEFIT? Referrals to S & C, Program Integrity What Does This Mean for Providers? Review PEPPER results MAC jurisdiction State National No GIP or CHC Long GIP Stays Reasons for no GIP Patient characteristics Hospital/SNF relationships 2

Focus on GIP Oversight focus on GIP Oversight focus on proper use of the levels of care Focus on GIP TPE Supplemental Medical Review Contractor (SMRC) StrategicHealthSolutions (Strategic) Post payment review 2015 claims GIP that may have been improperly paid 3

Two OIG Reports 2013 Medicare Hospice: Use of General Inpatient Care https://oig.hhs.gov/oei/reports/oei-02-10-00490.asp 2016 Hospices Inappropriately Billed Medicare Over $250 Million for General Inpatient Care https://oig.hhs.gov/oei/reports/oei 02 10 00491.asp The Facts OIG Report 2013 Medicare Hospice: Use of General Inpatient Care Based on GIP care provided in 2010 and 2011 Majority of GIP care provided in hospice inpatient units Hospices with inpatient units provided GIP care to more of their beneficiaries and for longer periods of time Some hospices did not provide any GIP Eight percent of all Medicare hospice dollars were for GIP care 67% of this was for GIP care provided in hospice inpatient units 4

The Facts OIG Report 2013 Medicare Hospice: Use of General Inpatient Care One third of GIP stays had length of stay (LOS) >5 days 11% LOS 10 days or more A total of 23% of hospice beneficiaries received GIP care in 2011 71% of these patients received GIP care at the beginning of their hospice election The Facts OIG Report 2013 Medicare Hospice: Use of General Inpatient Care OIG recommended: Further review of long GIP stays and GIP in inpatient units CMS should focus on hospices that do not provide GIP care and ensure that these hospices are providing beneficiaries access to needed levels of care at the end of their lives Suggested adopting a quality measure regarding hospices ability to provide all hospice services 5

The Facts OIG Report 2016 Hospices Inappropriately Billed Medicare Over $250 Million for General Inpatient Care Hospices billed one-third of GIP stays inappropriately Hospices commonly billed for GIP when the beneficiary did not have uncontrolled pain or unmanaged symptoms Ohio had many inappropriate GIP stays Hospices billed inappropriately for about half of GIP stays in SNFs Medicare sometimes paid twice for drugs for beneficiaries receiving GIP Hospices did not meet care planning requirements for 85 percent of GIP stays Hospices sometimes provided poor quality care and often did not provide intense services The Facts OIG Report 2016 Hospices Inappropriately Billed Medicare Over $250 Million for General Inpatient Care Recommendations CMS increase its oversight of hospice GIP claims and review Part D payments for drugs for hospice beneficiaries CMS should ensure that a physician is involved in the decision to use GIP CMS conduct prepayment reviews for lengthy GIP stays CMS Increase surveyor efforts to ensure that hospices meet care planning requirements CMS establish additional enforcement remedies for poor hospice performance 6

The Facts Other sources of GIP data: CMS Hospice Technical Reports Abt Associates MAC MedPAC The Concerns ARE PROVIDERS OFFERING THE FULL RANGE OF SERVICES? ARE PROVIDERS INAPPROPRIATELY ADMINISTERING THE BENEFIT? Referrals to S & C, Program Integrity 7

Definition In-patient care or services short term, general in-patient care provided directly by a hospice program in their own inpatient facility, through a contract arrangement with a licensed Medicare certified long term care facility, or hospital to provide pain and symptom management that cannot be accomplished in another setting. Regulations: General In Patient CoP 418.108 In-patient level of care must be made available for pain and symptom management as well as respite level of care in a participating Medicare or Medicaid facility. A hospice providing in-patient care directly must meet regulation specified in CoP 418.110. A hospice providing in-patient care under an arrangement agreement within a hospital or SNF must meet regulation specified in CoP 418.110(b) and (e) regarding 24 hour nursing and patient areas. 8

Service Level: In Patient Hospices that provide in-patient care directly must provide 24 hour nursing services that are sufficient to meet the total needs of the patient in accordance with the patient s plan of care. Each shift must include a registered nurse that provides direct patient care. The medical director or his/her designee may conduct regular on-site visits including daily visits if necessary. In Patient Eligibility General inpatient care may be required for procedures necessary for pain control or acute or chronic symptom management that cannot feasibly be provided in home settings. GIP under the hospice benefit is NOT equivalent to a hospital level of care. Skilled nursing care may be needed by a patient whose home support has broken down if this breakdown makes it no longer feasible to furnish needed care in the home setting. 9

In Patient Eligibility Pain Requiring: Delivery of medication which may require skilled nursing care for calibration, tubing change or site care/adjustment due to the complexity, nature of the medication and it s delivery system. Frequent evaluation/assessments by nurse or physician. Aggressive treatment to control pain that cannot be accomplished within the home setting. Frequent medication adjustments. In Patient Eligibility Symptom changes: Sudden deterioration requiring intensive nursing intervention. Uncontrolled nausea or vomiting. Pathological fractures. Respiratory distress that becomes unmanageable. Transfusions for relief of symptoms. Traction and frequent re-positioning requiring more than one staff member. Severe agitated delirium or anxiety or depression secondary to end-stage disease process. 10

In Patient Eligibility Imminent death alone is not the criterion for the GIP level of care! Symptom management that requires frequent skilled nursing intervention as evidenced by mottling, change in respiratory status and level of consciousness, etc. Symptoms related to imminent death which cannot be managed in the home setting. When GIP Is NOT Billable Caregiver breakdown, unless patient need meets criteria Patient admitted to hospice while in a hospital, SNF, or hospice inpatient unit, unless patient need meets criteria Unsafe/unclean home situation While awaiting nursing home placement Actively dying and not meeting the criteria for symptoms that cannot be managed in another setting 11

Criteria for Continued In Patient Eligibility Hospice is working aggressively to develop a plan for safe discharge. Ongoing mental status changes that require active treatment and frequent assessment. Pain continues to require active treatment and frequent assessment. Symptoms such as N/V, respiratory distress, open lesions, or ongoing deterioration require active treatment and frequent assessment. Acute symptoms have stabilized but death is imminent within a short period of time as evidenced by mottling, change in respiratory status and level of consciousness. Frequent skilled nursing intervention is needed. Requirements While Patient Receiving GIP IDG determines the level of care Patient does not need to change attending physicians Hospice inpatient cap Hospice-specific limitation Inpatient days billed to Medicare cannot exceed 20 percent of the total hospice days billed to Medicare 12

In Patient Discharge Eligibility Reason for admission stabilized. Re-established family support system. Appropriate safe discharge plan has been developed. Transfer to another level of care (i.e. respite). All of these reasons should be reviewed as a whole and not separately. Example 75 year old male patient; diagnosis of end stage Alzheimer's/dementia and comorbidities of type II diabetes, and CHF. Patient has Stage IV decubiti on the coccyx, oozing copious amounts of foul smelling drainage. Patient spiked temp of 103.2 (R). B/P 124/56 P 102 R 26. Patient is aphasic, but moans frequently. Wound cultures obtained. Roxanol administered every two hours. Patient begins vomiting and Phenergan is administered per rectum. Dressing changes to the decubiti required every four hours. Patient is on air mattress and requires two for turning and repositioning every two hours and prn. Source: Palmetto GBA Medicare Workshop 2015 13

Example 72 year old female patient who resides in a nursing facility. Diagnosis of End-Stage Alzheimer s and comorbidities of Type II diabetes, congestive heart failure, and renal disease. Patient is aphasic and lethargic. Patient requires frequent turning, mouth care, and personal hygiene. Patient has mottling in all extremities, and nail beds are cyanotic, Cheyne-Stokes respirations with a respiratory rate of ten. Pulse is 106 and thready. Blood pressure inaudible. Slight rales noted bilaterally. Source: Palmetto GBA Medicare Workshop 2015 GIP Scenario A 67 yo male patient with diagnosis of stage IV pancreatic cancer. Patient resides at home with his wife who is the primary caregiver. Patient has been having increasing bouts of pain with vomiting. Patient is receiving sublingual morphine every 2 hrs for break through pain and phenergan suppositories for vomiting. Patient is alert and conversive. At 2:00 a.m. the wife calls the hospice nurse to report that the pain medication is not relieving the pain. Source: NGS Hospice Nursing Documentation: Meeting Terminal Prognosis and Level of Service 14

GIP Scenario: Poor Supporting Documentation 07/02/2010 2:15 a.m. patient experience pain, medication administered without relief. Patient is exhibiting severe pain. Physician notified, new orders received and noted. Ambulance called to transport patient to the inpatient unit. 07/03/2010 10:15 a.m. visit note-patient admitted to hospice facility for inpatient care due to uncontrollable pain. Met with family and they are pleased with the care. Patient s symptoms are controlled with the initiation of a pain pump. Assessment completed and noted. Source: NGS Hospice Nursing Documentation: Meeting Terminal Prognosis and Level of Service GIP Scenario: Better Supporting Documentation 07/02/2010 2:15 a.m. Patient experiencing pain not relieved by sublingual morphine. Physician called and new orders noted to transfer patient to the inpatient unit for initiation of pain pump. Ambulance called and patient transported. The patient s wife is unable to meet the increased needs of the patient, and has no other family members for support. 07/03/2010 10:15 a.m. Nursing staff reports the patient s pain is only minimally controlled with pain pump. Patient has had several episodes of vomiting and given phenergan IV. Patient is non- responsive except to painful stimuli. Moans frequently. Patient requires two for turning, repositioning and performing personal care. Assessment completed and noted. Oxygen was initiated at 2 Liters via nasal cannula for Oxygen saturations of 88%. O2 sat is 98% on 2L/per min. Source: NGS Hospice Nursing Documentation: Meeting Terminal Prognosis and Level of Service 15

In Patient Documentation Tips Do Discharging planning begins on the first day of in-patient level of care and continues throughout the in-patient level stay. Document the team s effort to resolve patient problems at the lowest level of care. Address discharge plans and why patient remains eligible for in-patient level of care. Explain why care must be provided in the in-patient setting and not at home e.g. patient requires frequent RN/NP/MD assessment and titration of medication to control pain. In Patient Documentation Tips Do Describe services provided. Think of your note as a bill to Medicare. Each note must stand alone. Document the context and the events that led to the inpatient level of care. Document the failed attempts to control/manage symptoms prior to in-patient level of care admission. Document care that caregivers cannot manage at home. (frequent changes in medication/medication titration etc.) 16

Do In Patient Documentation Tips Document specific symptoms that are being addressed (uncontrolled n/v, new agitation/delirium). Describe failed attempts to manage these at home. Document progress/context/changes including: symptomatic imminent death that cannot be managed at home because. Document patient response to interventions provided on the in-patient level of care (Were they effective? Are they still effective?). In Patient Documentation Tips Don t Don t use patient is dying, end-oflife care, general decline or medication adjustment to justify inpatient level of care unless you ALSO document why these actions cannot take place in the home. Don t document resolution of the precipitating events that led to inpatient level of care without further documenting eligibility that maintains in-patient level of care status 17

Documentation Tips Create a snapshot that will paint a picture of the patient s needs and what the care needs entail. The picture you paint is the picture Medicare will use to determine whether this level of care is appropriate and reimbursable. Katie Wehri, CHPC Director of Operations Consulting Kwehri@healthcareprovidersolutions.com 18

References IAHHC (2012) Hospice General Inpatient Criteria, Strauss and Wehri CFR Title 42- Public Health, Part 418-Hospice Care Electronic Code of Federal Regulations (2012) Hospice & Palliative Care Federation of Massachusetts (2008), The Hospice General In-Patient Level of Care; Criteria, Guidelines, Reimbursement and Contracting Medicare Benefit Policy Manual, Chapter 9 https://www.cms.gov/manuals/downloads/bp102c09.pdf CMS State Operations Manual, Appendix Mhttps://www.cms.gov/Regulations-and- Guidance/Guidance/Manuals/downloads/som107ap_m_hospice.pdf Medicare Claims Processing Manual, Chapter 11http://www.cms.gov/Regulations-and- Guidance/Guidance/Manuals/Downloads/clm104c11.pdf Katie Wehri, CHPC Director of Operations Consulting Healthcare Provider Solutions, Inc. 810 Royal Parkway, Suite 200 Nashville, TN 37214 615.399.7499 615.399.7790 info@healthcareprovidersolutions.com www.healthcareprovidersolutions.com 19