As scrutiny of hospice organizations increase, it’s particularly important for hospices to ensure their certifications and recertifications of terminal illness meet all required elements.  In the 2021 Medicare FFS Supplemental Improper Payment Data report of improper payments, the top cause for error was “insufficient documentation of the physician’s certification/recertification”.  A few short months from now,…

Spring in the United States brings more than beautiful flowers and green grass.  In fact, this Spring has brought snow storms, wildfires, floods, and deadly tornadoes.  The Conditions of Participation for home health, hospice, and many state licensed home services require the establishment of an emergency plan for its organization, employees, and patients. In addition…

  Sigh.  Raise your hand if you thought this virus would be gone by now.  The healthcare community and public are being overloaded with information—masks or no masks, boosters or no boosters—and on and on.  OSHA recently announced it is holding public hearings in the next 10 days regarding a final standard to protect healthcare…

CMS recently updated the Code of Federal Regulations for Home Health Services (Part 484) as well as the Medicare Benefit Policy Manuals—Chapter 7 for Home Health Agencies.  The changes reflect alterations in the Conditions of Participation released in the home health final rule last year and became effective on January 1, 2022.  There is always…

Both home health agencies and hospices may care for patient wounds in the course of their work.  Wound care may involve treatment of ulcers, burns, pressure sores, open surgical sites, fistulas, tube sites, and tumor erosion sites as well as other types of wounds.  The challenges of wound care include several factors—accurate assessment of the…

The Final Rule for hospice 2022  included the retirement of public reporting of seven Hospice Item Set (HIS) measures.  These were replaced with a claims-based composite item called the Hospice Care Index (HCI).  This new item will be publicly reported no sooner than May 2022.  In case you missed it or need a refresher, there…

The Quarterly OASIS Q&As were released in January.  Interestingly, there were a number of questions regarding medication management, specifically OASIS items M2020 and M2030.  Determination of the patient’s ability to manage oral and/or injectable medications can be tricky for the assessing clinician. Direct observation is the preferred assessment method.  Clinicians need to observe the patient’s…

The Review Choice Demonstration (RCD) selection period is currently open for Illinois (Cycle 5) and Texas (Cycle 4) from March 1, 2022 through March 16, 2022. Selections made during this time will go into effect on April 1, 2022. Providers that DO NOT MAKE A SELECTION will automatically be placed in a default category based…

Just last month, the Office of Inspector General (OIG) announced its intent to perform a nationwide review of hospice beneficiary eligibility.  This action was in response to identified recent negative findings during individual provider audits by the Office of Audit Services.  In their audits, they found a pattern of patients who did not meet eligibility…

When it comes to the Conditions of Participation for both home health care and hospice, there are different sources for this information.  Organizations often search the State Operations Manual (SOM) for CoPs.  However, it’s important to remember that this document is a guide for state surveyors and doesn’t contain other information such as Conditions for…