Hospices must pay close attention to regulatory compliance when transitioning hospital-bound patients to the General Inpatient (GIP) level of care.

The U.S. Centers for Medicare & Medicaid Services (CMS) has indicated that a GIP stay is appropriate when patients require pain control or chronic symptom management that cannot be delivered in any other setting. GIP may also be appropriate if a patient is in need of medication, adjustment, observation or other stabilizing treatment.

These stays are intended to be short term, and the agency often audits hospices who provide GIP for longer than six days, according to Bryan Nowicki, partner at the law firm Husch Blackwell.

“[CMS] says that a brief period of General Inpatient Care may be needed in some cases when a patient elects the hospice benefit at the end of a covered hospital stay,” Nowicki said in a recent Husch Blackwell podcast. “So in advocating these cases, if we have a patient who has come off of a hospital stay, admitted to the hospice or GIP, and, for some reason, that claim was denied, we’re pointing that out to the decision makers in the appeal process is this falls right into what CMS has identified as kind of a classic example of the appropriateness for GIP, and the documentation should reflect that.”

As in virtually all things regulatory, effective clinical documentation is crucial, according to Nowicki. Documentation must clearly demonstrate that the patient’s needs could not be addressed in another setting. It must also draw the connection between the covered hospital stay and the transition to GIP, he said. These are key questions that administrative law judges (ALJ) often ask during hospices’ appeals of claims denials.

One way to strengthen clinical documentation is to keep physicians involved on a daily, real-time basis, according to Meg Pekarske, partner at Husch Blackwell.

“Make sure that your physician is very involved in terms of documentation of eligibility for this level of care, not just the nurse. People get an order from a physician for level of care changes. It’s a very common practice and a best practice. But also, that’s not a one and done,” Pekarske said in the podcast. “Keeping your hospice physician engaged … a physician can really be a dot connector as to why this level of care is needed on a real time basis.”