As hospices seek to keep up with the demand for general inpatient care, careful attention to documentation is essential to avoid potential audits by the U.S. Centers for Medicare & Medicaid Services (CMS) or other agencies.
Patients are admitted to inpatient hospice care when their symptoms are too severe to manage in the home, or when they lack sufficient caregiver support in the home. Associated documentation must clearly establish the patient’s need for inpatient care. Inaccuracies or inconsistencies in patients’ documents could attract the attention of regulators.
“These [four hospice] levels of care are paid at different rates, so you can understand that as much as possible CMS wants to provide routine home care, which is the most cost efficient way of providing care to a hospice patient,” Laura Page-Greifinger, consultant with McBee Associates, said at the National Hospice & Palliative Care Organization’s Interdisciplinary Conference. “[General inpatient care] is the level most audited by CMS, and it’s the most often denied when a review is done — and basically, it is the documentation.”
Hospices can provide general inpatient care in their own inpatient units or in a contracted facility such as a Medicare-certified hospital. CMS considers this to be short-term care, with five consecutive days considered a long length of stay, according to Page-Greifinger.
Payment to hospices for that level of care has changed as of this year, with rising costs provoking more regulatory scrutiny.
CMS rebased payment rates for the four levels of hospice care in a final rule for Fiscal Year 2020. The rule instituted a 2.7% cut in routine home care payments and a corresponding 2.7% increase in payments for continuous home care, general inpatient care, and inpatient respite care. Prior to this rebasing, payment rates for those three levels of care amounted to less than the cost of providing those types of care.
Submitting inadequate or incomplete required written documentation is a sure-fire way to bring surveyors or auditors to a hospice’s doorstep. As regulators increasingly fix their eyes on the hospice space, providers need to ensure their documentation is airtight.
‘Each day of [general inpatient] care must be supported in the documentation. Staff need to be educated in this fact and really understand that their documentation is key,” Page-Greifinger said. “Documentation tells the patient’s story. It has a beginning, a middle and an end. The importance of clinical documentation cannot be over-explained. The goal is always to focus on a patient-centered, data-driven, outcome-oriented documentation process that always shows high-quality patient care in real time for all patients and ensures compliance.”
Documentation must accurately reflect the patient’s conditions, abilities and environment, including what caused the placement in general inpatient care. Page-Greifinger said hospices should document the interventions in which they tried and failed at other levels of care.
“The goal should always be a well-written story of the patient on hospice service, in which any review gives a picture of the patient,” Page-Greifinger said. “Telling the story of a hospice patient on [general inpatient] level care will be the difference in getting paid for the care provided or providing the care for free.”