Hospice Audit Findings and New Notification of Election Form
||Participating Hospice Providers|
||April 7, 2014|
||Hospice Audit Findings and New Notification of Election Form|
The Department of Health and Human Services, Office of Inspector General, recently completed an audit of Illinois Medicaid-reimbursed hospice care services. As a result of that audit, the Department of Healthcare and Family Services (HFS) is notifying hospices of some specific areas of concern, and issuing a standardized Notification to HFS of Illinois Medicaid Hospice Benefit Election form, to help ensure the integrity of the Illinois Medicaid hospice benefit.
Timely Physician Certification of Terminal Illness
The State Medicaid Manual, Chapter 4, issued by the federal Centers for Medicare and Medicaid
Services, specifies that hospices must obtain, no later than two calendar days after hospice care is initiated, written certification statements signed by the medical director of the hospice or the physician member of the hospice interdisciplinary group and the individual’s attending physician (if the individual has an attending physician).
If the hospice does not obtain a written certification within two days after the initiation of hospice care, a verbal certification may be obtained within these two days, and a written certification obtained no later than eight days after care is initiated. If these requirements are not met, no payment can be made for days prior to the certification. The attending physician is a physician who is a doctor of medicine or osteopathy and is identified by the individual at the time he or she elects to receive hospice care as having the most significant role in the determination and delivery of the individual’s medical care.
For any subsequent period, the hospice must obtain, no later than two calendar days after the beginning of that period, a written certification statement prepared by the medical director of the hospice or the physician member of the hospice’s interdisciplinary group. The certification must include the statement that the individual’s medical prognosis is that his or her life expectancy is six months or less if the terminal illness runs its normal course and the signature(s) of the physician(s). The hospice must retain the certification statements.
Health Care Worker Registry
Hospices must check the Health Care Worker Registry for all new employees who fall under the requirements of the Health Care Worker Background Check Act (225 ILCS 46). The Health Care Worker Registry is maintained by the Illinois Department of Public Health and lists individuals with a background check conducted pursuant to the Act. It identifies training information for certified nursing assistants and other health care workers. Additionally, it displays administrative findings of abuse, neglect or misappropriations of property. Staff licensed by the State of Illinois (such as registered nurses and physicians) are exempt from the requirements of this Act.
Notice of Election for Hospice Care
Hospice providers must capture all of the information required for hospice election, as identified in the State Medicaid Manual, Chapter 4. Additionally, providers must make potential adult patients age 21 and over aware of HFS hospice rules at 89 Illinois Administrative Code Section 140.469 that identify restrictions on certain services and items, even if those services or items are unrelated to the terminal illness. Pursuant to Section 2302 of the Affordable Care Act, titled “Concurrent Care for Children,” election statements for children through age 20 cannot require that the patient waive other Medicaid-covered curative treatment. Election statements must inform pediatric patients that they are entitled to all Medicaid benefits concurrently with hospice care.
Hospices must retain all Notice of Election forms and be able to produce them upon request of HFS or its designated entity.
Notification to HFS of Illinois Medicaid Hospice Benefit Election
To better track the election status of hospice patients, HFS has made available a standard form that must be submitted to HFS for each hospice patient who elects hospice care. This form must also be submitted to the department when a patient dies, ceases hospice care, or transfers to another hospice. This notification form has been designated the HFS 1592 and is available in PDF-fillable format on the Medical Programs Forms Page of the website. Effective May 1, 2014, use of this form is mandatory. Hospices are asked to allow two weeks after submittal of the HFS 1592 before submitting a claim.
If a patient is covered under a managed care entity (MCE) contracted with HFS, hospice providers must also submit a copy of the HFS 1592 form to the MCE.
Any questions regarding this notice should be directed to the hospice’s billing consultant in the Bureau of Hospital and Provider Services 1-877-782-5565.
Theresa A. Eagleson, Administrator
Division of Medical Programs