You do not need to be afraid of the RACs. Making certain that your hospice can withstand whatever RAC scrutiny may come your way is not as hard as it may seem at times. The RACs are not yet targeting hospices and there is an opportunity NOW to make certain that each and every claim submitted for payment is for care provided to patients that are eligible for hospice and/or for the level of care provided.
The RAC look back period is for three years – so maybe there is not a lot you can do about claims submitted in 2008 or the early part of 2009. But there is a lot that can be done to ensure that no claims submitted from this day forward will be denied or, if they are, that you are confident any denials can be overturned on appeal.
Here is what you need to do:
- Ensure that you are using valid notices of election and certification and recertification of terminal illness forms that are signed and correctly dated.
- Make certain that whenever a request for medical records is received, all the requested information is sent by the required date.
- Do not admit patients who are not eligible for hospice care.
- Do not provide the general inpatient care or continuous care to patients who do not need it.
- Ensure that documentation in each patient’s clinical record supports the patient’s eligibility for hospice care for everyday the patient receives hospice care.
- Ensure that documentation in the clinical record for each patient receiving general inpatient or continuous provides evidence supporting the need for the higher level of care.
So that is it. There may be more to it, but these six things are the most important.
Hundreds of hospices have lost thousands of dollars in denied claims from their RHHIs/Fiscal Intermediaries because the clinical record of the patient whose claim is denied does not contain adequate documentation from members of the IDG to support the patient’s eligibility. For years we have heard the old adage “if it is not documented it is not done.” It is time to scream that from the rooftops to hospice interdisciplinary groups across the country and do whatever is necessary to impress upon clinicians that the financial viability of their hospice program (and security of their jobs) is dependent upon the quality of their assessments and the documentation of eligibility for each patient. Hospices need to make certain they are providing the tools, resources and training that members of the IDG need in order to ensure that their documentation accurately reflects the patient’s eligibility for hospice.
Today is a good day for hospices to make a firm commitment to do everything possible to put the RACs out of business. Perhaps that is too lofty - who cares if they go out of business? What matters is that your RAC does not get any business or repeat business from you.

Subscribe to RSS


