CMS has long taken the position that “services unrelated to the terminal illness and related conditions should be exceptional, unusual and rare given the comprehensive nature of the services covered under the Medicare hospice benefit…” So it is no surprise that as part of the FY2020 Hospice Wage Index Final Rule, hospices will be required to notify beneficiaries (or their representatives) of their right to receive an election statement addendum that includes a list of and rationale for any conditions, items, services, and drugs that hospice deems as unrelated to the terminal prognosis. CMS indicates that the amount of items being billed to Medicare outside of the hospice benefit is greater than it would expect if hospices were universally applying a holistic, comprehensive approach to hospice care. In addition to improving hospice adherence to coverage requirements, the addendum will also help ensure coverage transparency.
Starting October 1, 2020, if a beneficiary requests the addendum at admission, hospices will be required to provide a detailed addendum within 5 days of admission. If requested after the start of care, the addendum must be provided within 72 hours. The short turnaround time necessitates that hospices be proactive and strategic in their documentation to make it easy to generate an accurate, complete addendum when needed.
To simplify the addendum process, it would behoove hospices to consider the following:
- Is hospice staff well educated on determining what is and is not related to each patient’s terminal prognosis? If not, consider providing each with a copy of NHPCO’s “Determining Relatedness to the Terminal Prognosis Process Flow” as a training tool.
- Is entry of all diagnoses, drugs, durable medical equipment (DME), and services and their related/unrelated status into the appropriate fields in the EMR prioritized at admission?
- Are the same principles of relatedness and unrelatedness being applied for all patients?
- Do they have a single document in their EMR that includes a list of all unrelated diagnoses, medications, items, and services?
- Do they have a single document in their EMR that includes, in language that would be understood by the beneficiary and his or her representative, an explanation of why the listed unrelated diagnoses, medications, items, and services are considered unrelated to the terminal prognosis and not necessary for symptom management?