Hospices Can’t Use Telehealth for SIA Claims During Pandemic

Hospice providers cannot use telehealth visits to qualify for service intensity add-on payments during the COVID-19 pandemic.

The U.S. Centers for Medicare & Medicaid Services (CMS) in recent days has announced a series of new flexibilities that allow hospices to perform more functions via telehealth than were previously allowed. The recent $2.2 trillion CARES Act stimulus package, designed to help the economy and essential industries weather the impact of the pandemic, also contains provisions related to hospice telehealth, including permitting practitioners to recertify patients via telemedicine appointments rather than face-to-face encounters.

While many in the field see these flexibilities as a boon, the rules don’t allow them to collect SIA payments for services rendered via telehealth.


“The SIA is paid for visits in the last seven days of life, and so the current thinking is telehealth would be part of the routine home care rate and would not rise the level of requiring us to pay an add on for that,” said Hillary Loeffler, director of the Division of Home Health and Hospice at CMS.

SIA was introduced in 2016 to allow hospices to bill an additional payment on an hourly basis for registered nurse and social worker visits during the last seven days of a patient’s life in addition to their standard per diem reimbursement.

The number of registered nurse and social worker visits during a patient’s final week is one of the seven quality measures that CMS uses to evaluate providers for its Hospice Compare website, which allows consumers, payors, and referring organizations to benchmark performance of individual providers against one another. SIA providers a financial incentive for hospices to improve performance on the measure.


CMS requires hospice providers to submit data for two measures pertaining to the number of visits a patient receives when death is imminent. The three-day measure assesses the percentage of patients receiving at least one visit from a registered nurse, physician, nurse practitioner, or physician assistant in the last three days of life. The seven-day measure assesses the percentage of patients receiving at least two visits from a social worker, chaplain or spiritual counselor, licensed practical nurse, or hospice aide in the last seven days of life.

Loeffler indicated in a CMS conference call that the agency would be willing to consider allowing hospices to use telehealth for visits that would qualify for SIA down the road.

“That’s something that we can take back and think about further,” she said. “We can definitely take that back for consideration.”

In the meantime, in addition to allowing hospices to recertify patients via telehealth, CMS is allowing providers to conduct routine home care visits online as long as those services are consistent with the patient’s care plan. The agency has also waived the rule requiring a nurse to conduct an onsite visit to evaluate whether aides are providing care consistent with the patient’s care plan. Further, the agency has waived the requirement that volunteers provide 5% of patient care hours and extended the timeframe for updating a patient’s comprehensive assessment to 21 days.

“Every day, heroic nurses, doctors, and other health care workers are dedicating long hours to their patients. This means sacrificing time with their families and risking their very lives to care for coronavirus patients,” said CMS Administrator Seema Verma. “Front line health care providers need to be able to focus on patient care in the most flexible and innovative ways possible. This unprecedented temporary relaxation in regulation will help the health care system deal with patient surges by giving it tools and support to create non-traditional care sites and staff them quickly.”