Do we need a separate order to admit to hospice aside from the initial certification? We had been sending out orders after receiving the referral and deeming the person eligible, requesting order for admission to hospice care and with a specified diagnosis. Is that necessary or can just the initial certification serve as our order?
Per the Conditions of Participation, you do not need a separate order to admit a patient to hospice. What you need is an oral certification if you cannot get a written certification within 2 calendar days. Palmetto and the Centers for Medicare and Medicaid Services (CMS) have given guidance on oral certifications. If a nurse calls the doctor and asks the doctor if the patient qualifies for hospice and should be certified for hospice (oral certification) then that nurse can document the oral certification in the medical record and that documentation is sufficient until the doctor signs the written certification. Some programs insist the attending physician or medical director sign the oral certification, but it is not a CMS requirement.
418.22(a) (3) states “(3) Exceptions. (i) If the hospice cannot obtain the written certification within 2 calendar days, after a period begins, it must obtain an oral certification within 2 calendar days and the written certification before it submits a claim for payment.”
And 418.22(d) states “(d) Maintenance of records. Hospice staff must—
(1) Make an appropriate entry in the patient's medical record as soon as they receive an oral certification; and
(2) File written certifications in the medical record.”
Does a re-certification/ face-to-face (F2F) need to occur 15 days prior to the end of the certification period?
This question has a fairly confusing answer, due to the regulations.
The CoP’s say the F2F can be done up to 30 days prior to the recertification period, BUT the recertification can only occur no more than 15 days prior to the next certification period. So the physician or Nurse Practitioner (NP) can perform the F2F encounter much sooner than the recertification. Please pay attention to both timeframes so you don’t get them mixed up or confused.
A lot of programs have their medical directors go out within 15 days of the next certification period and have them do the F2F and recertification all at the same time. If an NP is doing the F2F encounter, just make sure the hospice physician still has the recertification completed within the 15 day timeframe.
418.22. (a)(3)(iii) states “(iii) Recertifications may be completed no more than 15 calendar days prior to the start of the subsequent benefit period.”
And 418.22 (a)(4) states “(4) Face-to-face encounter. As of January 1, 2011, a hospice physician or hospice nurse practitioner must have a face-to-face encounter with each hospice patient whose total stay across all hospices is anticipated to reach the 3rd benefit period. The face-to-face encounter must occur prior to, but no more than 30 calendar days prior to, the 3rd benefit period recertification, and every benefit period recertification thereafter, to gather clinical findings to determine continued eligibility for hospice care.”
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