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The Changing Requirements of HMDs
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This document discusses telehealth best practices, the Notice of Election (NOE) addendum, and general inpatient care in hospice. Telehealth has been greatly advanced during the COVID-19 pandemic, with patients and physicians showing high acceptance and confidence in its use. However, there are concerns from CMS about widespread telehealth utilization leading to increased costs. Telehealth is currently utilized in hospice under Public Health Emergency (PHE) waivers, but CMS is reluctant to accept these waivers as permanent due to potential billing issues.<br /><br />The NOE addendum addresses the relatedness of diagnoses and conditions to a patient's terminal illness, stating that hospices are responsible for providing care related to the terminal diagnosis, as well as related conditions and other diagnoses that contribute to the six-month prognosis. The addendum notifies patients of non-covered items, services, and drugs that are determined to be unrelated to their terminal illness. There are concerns about "leakage" of services and medications that should be covered by hospice but are instead paid for by Medicare. Patients should be informed about the coverage decisions and reasons for non-coverage.<br /><br />General inpatient care (GIP) is one of the four levels of hospice care and is used for pain and symptom management that cannot be achieved at a lower level of care. Accurate documentation is essential for ongoing eligibility, and failure to document properly can lead to compliance issues. Discipline-specific education, documentation of failed attempts at symptom control, and discharge planning from the time of admission are crucial for success in GIP care. Audit programs and addressing families who refuse to leave the inpatient setting are also important.<br /><br />Proper documentation, involvement of the hospice physician in care decisions, and education on GIP requirements are emphasized to avoid inappropriate billing and comply with regulations. Resources such as the Medicare Benefit Policy Manual, Palmetto GBA Audit Tool, and NPHCO Clinical Guide to Hospice GIP are recommended for further reference.
Keywords
telehealth
NOE addendum
inpatient care
hospice
COVID-19 pandemic
billing issues
terminal illness
Medicare
GIP
documentation
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