Initial Certification of Terminal Illness Checklist
Initial Certification of Terminal Illness Checklist
VERBAL CERTIFICATIONS
CATEGORY/REQUIRED AREA INITIAL CERTIFICATION
Benefit Period Certification Language Hospice Physician Serving as Attending Medical Director/Hospice Physician
Space for benefit period begin/end dates
Correct certification wording included "Life expectancy of six months or less if disease runs its normal course"
If applicable, statement present to note medical director or hospice physician is designated as attending Line to print name of staff member who received verbal cert. (optional but wise with increasing focus on legible signatures)
Line to print name of physician providing verbal certification
Signature line for person taking verbal certification
Attending Physician
Line for date verbal certification received Line to print name of staff member who received verbal cert. (optional but wise with increasing focus on legible signatures)
Line to print name of physician providing verbal certification
Signature line for person taking verbal certification
Line for date verbal certification received
Hospice Physician
Signature line
Line for signature date
Line to type or print physician's name to ensure legibility
Attending Physician
Signature line
Line for signature date
Line to type or print physician's name to ensure legibility
PHYSICIAN SIGNATURES
NARRATIVE OPTION 1
If the narrative is part of the certification form, narrative and attestation (see below) located immediately prior to the physician's signature
NARRATIVE OPTION 2
If the narrative exists as an addendum to the certification form, in addition to the physician's signature on the certification form, place for the physician to sign immediately following the narrative and attestation (see below) on the addendum
NARRATIVE
The narrative includes a statement directly above the physician signature attesting that by signing,
ATTESTATION the physician confirms that he/she composed the narrative based on his/her review of the patient's medical record or, if applicable, his or her examination of the patient
Questions? Comments? Visit or call us at 919-491-0699. We'd love to hear from you.
Recertification of Terminal Illness Checklist
CATEGORY/REQUIRED AREA INITIAL CERTIFICATION
Benefit Period Certification Language Hospice Physician Serving as Attending
Space for benefit period begin/end dates
Correct certification wording included "Life expectancy of six months or less if disease runs its normal course"
If applicable, statement present to note medical director or hospice physician is acting as attending
Medical Director/Hospice Physician
Line to print name of physician providing verbal certification Line to print name of staff member who received verbal cert. (optional but wise with increasing focus on legible signatures) Signature line for person taking verbal certification
Line for date verbal certification received
VERBAL CERT.
SIGNATURE
PHYSICIAN SIGNATURE
Signature line Line for signature date Line to type or print physician's name to ensure legibility
NARRATIVE OPTION 1
If the narrative is part of the certification form, narrative and attestation (see below) located immediately prior to the physician's signature
NARRATIVE OPTION 2
If the narrative exists as an addendum to the certification form, in addition to the physician's signature on the certification form, place for the physician to sign immediately following the narrative and attestation (see below) in the addendum
NARRATIVE
The narrative includes a statement directly above the physician signature attesting that by signing,
ATTESTATION the physician confirms that he/she composed the narrative based on his/her review of the patient's medical record or, if applicable, his or her examination of the patient
Questions? Comments? Visit or call us at 919-491-0699. We'd love to hear from you.
Face-to-Face Encounter Documentation
FFE DOCUMENTATION MUST INCLUDE
Separate and distinct section of, or an addendum to, the recertification form Form or section of the form is clearly titled Includes attestation statement directly above the physician / NP signature Attestation statement contains the following
date of visit name of patient (if not already on the form) signature of the physician / NP who made the visit signature date If face-to-face encounter completed by a NP, attestation must also state that the clinical findings of that visit were provided to the certifying physician, for use in determining whether the patient continues to have a life expectancy of 6 months or less, should the illness run its normal course.
Questions? Comments? Visit or call us at 919-491-0699. We'd love to hear from you.
Face-to-Face Process Table
1
TASKS
PERSON RESPONSIBLE COMPLETE BY
Identify Medicare patients that will require a FFE
Identify patients with 3rd or subsequent recertification periods occurring in January and get them on a calendar and block out the 30-day window Looking forward, project the anticipated volume of FFEs per month to determine staffing needs
Have a failsafe system in place to identify 30 days ahead who will need a FFE
Put someone in charge of "The List" Get FFEs scheduled so everyone has enough time to plan Follow-up to make sure they are done timely
Determine who will do the FFEs
Once you have an idea of volume, determine who will do the FFEs. This may be the toughest challenge of all and we can't offer too much help other than to remind you of the requirements.
1. Physician ? employed contracted or volunteer 2. Nurse-practitioner ? employed or volunteer (remember that employed
does not mean a full/part time position; it can be a per diem (as needed) position)
Orient them
Determine processes and policies to be written or revised
Start with policies related to certification, recertification, and admissions. If using an EMR, contact your software vendor to determine what they are doing to assist with this change and when it will be released
Tracking FFE Note FFE Attestation Communication and flags to billing
Think through the current process for recertifications at your IDG meetings
This may affect you current process for recertifications at the IDG meetings. If the practitioner who does the FFE is not at the IDG meeting, it will most likely change the way IDG meetings are run and how the recertifications are completed (FFE, Narrative, and Certification statement). It is possible that the FFE may be completed by someone other than the team physician.
It could be one of the following two options
1. FFE by NP then information to certifying physician who then writes the narrative and provides/signs the certification statement
2. FFE by certifying physician who then writes the narrative and provides/signs the certification statement
Develop new or revise current forms
FFE clinical note and attestation Narratives and attestation Recertification statements Initial certification statements
Collaborate and develop process with billing department
How will billing department know
1. When it's okay to bill 2. What days to bill for 3. Who will monitor the requirements before billing
How good is your process for physician billing right now?
1. Identify what (if anything) needs to change if the volume increases? 2. Do you feel like you have a good system for documentation,
processing and billing? 3. If the volume increases will this impact aggregate Cap? 4. How will you audit physician billing?
Questions? Comments? Visit or call us at 919-491-0699. We'd love to hear from you.
TASKS
2 PERSON RESPONSIBLE COMPLETE BY
How will everyone who needs to know about these changes learn about them and their roles?
Training sessions Plan Schedule Deliver and track
Necessary on-going tracking
Determine who will track the process to ensure that the following steps get completed timely
FFE completed 1. Clinical supporting note completed and turned in 2. Content supports eligibility and is not just a H&P 3. Attestation completed and turned in If billable services were provided 1. Clinical note completed and turned in 2. CPT code determined Narrative with attestation completed and turned in Narrative incorporates findings from FFE to support eligibility All the signatures are legible or the signature is above the printed name
Coordination with Medical Records
1. Have the forms been developed to make it easy to identify the patient and date? (Just ask the medical records clerk how much quicker it makes it for him/her to file when the names and dates are all in the same place)
2. Where will the new forms be filed?
New referrals / admissions coming into a 3rd or subsequent benefit period
Will you admit patients prior to determining if they have received hospice services before? Determine your company stance and policy on this issue now because at times it may be impossible to check the Medicare system quickly.
Implement a process to check on benefit periods upon referral 1. Normal business hours 2. After hours Investigate the different paths / methods to verify benefit periods when the CWF is not available (see page 378 of the preamble to final rule) Write up procedure Determine how on-call staff will handle
Transfers
Establish internal procedure that incorporates the following steps:
Check Medicare file for benefit period Put on calendar if coming up in next 30 days Make sure to enter the benefit periods properly into tracking/software system Obtain copies of most recent certification / recertification documentation
1. FFE clinical note and attestation if applicable 2. Narrative and attestation 3. Certification statement Have your hospice physician review the case and then provide a new certification statement (dates of benefit period don't change)
Changes to compliance plan audit / monitoring plan
Revise your compliance audit plan to incorporate this new requirement.
Consider a pre-billing audit in January before December bills are submitted
and again in February before January bills are submitted.
Projecting financial impact of the new requirement
Determine costs of FFE and include in your budget. 1. Staffing costs 2. Travel costs 3. What will be offset by billable visits when the services
provided are reasonable and necessary?
Don't let the pendulum swing too far in the other direction. Put balancing measures in place to ensure you continue to admit and recertify all eligible patients. Is more education needed on how to identify eligible patients, how to document end-stage disease trajectory so the story is told?
Create a tracking system and monitor results closely. 1. Track the live discharges for no longer eligible 2. Put a system in place to keep in contact with the patient/family to determine when it might be time to re-evaluate and readmit. Determine if the right choice was made.
Realistically determine and track how this may affect census by potentially increasing your discharges. What impact might this have on your budget? If necessary, start preparing now.
Questions? Comments? Visit or call us at 919-491-0699. We'd love to hear from you.
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