1. Does medication coverage change in the 2017Final Rule?Answer: No, the 2017 Final Rule does not changethe coverage requirements for patient medications.Hospice is still responsible for virtually allmedications, over-the-counter and prescribed, thatare medically necessary for palliation of the hospicepatient’s symptoms.

2. How will payment be affected if a patient refusessocial work and spiritual services? We have seenthis on a few occasions.Answer: If the patient refuses social work orchaplain services, you should document that inthe record. The per diem payment would notbe affected as long as nursing and other orderedservices are being regularly provided based on thePlan of Care. However, without social work, serviceintensity add-on (SIA) payment potential decreases.

3. In Measure 1 of the new quality measures, doesan LPN visit count as a nurse visit in the last threedays, or does Measure 1 mean RN only?Answer: No. Measure 1 applies to patients whoreceive at least one RN, NP, physician or PA visit inthe last three days of life. The second metric underthe imminent death measure includes LPN/LVNand/or Aide visits during the last seven days of life.

4. What happens with the end of life visitreimbursement if continuous care is involved?Answer: The service intensity add-on (SIA)payment is based on routine home care only.Continuous care during the last days of life wouldbe reimbursed at those rates without the add-on.

5. Should the new quality measures be includedin our Quality Assurance and PerformanceImprovement (QAPI)? Or, will this be added to theHIS Measure?Answer: The new quality measures will becomepart of the HIS beginning April 1, 2017. Watch forthe training that CMS promises to provide hospiceproviders. Certainly you should track the elementsof each measure in your QAPI to ensure attentionto these target areas identified both by CMSauditors and hospice PEPPERs.

6. Regarding hospice star ratings, will the CAHPSstars be separate from HIS stars, or will it be onecombined star rating?Answer: They will be separate ratings. Take a peekat Home Health Compare for an example of howHospice Compare will separate the CAHPS andpatient care quality ratings.

7. In the statement, “Unless there is clear evidencethat a condition is unrelated to the terminalprognosis,” what do they mean by “clear evidence?”Answer: The record should include documentation, offered by the physician, about exactly why aparticular condition is unrelated to the terminalprognosis.

8. If a patient has a hospice diagnosis of metastaticlung cancer, but wants to continue dialysis, is thehospice is responsible for the dialysis?Answer: Patients are able to qualify for hospiceand end stage renal disease (ESRD) benefits at thesame time as long as the dialysis is not related tothe patient’s terminal condition and the patient

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WEBINAR FOLLOWUP

Frequently Asked Questions about

The 2017 Hospice Final Rule

by SHARON S. HARDER, President of C3 Advisors

& BETH NOYCE, RN, BSJMC, HCS-H, HCS-D, COS-C of Noyce Consulting

We asked Sharon Harder of C3 Advisors and Beth Noyce, RN, BSJMC, HCS-H, HCS-D, COS-C of Noyce Consulting to answer the most popular questions from their recent webinar, The 2017 Hospice Final Rule. This important 60-minute webinar is now available on-demand at www.kinnser.com/hospice2017. Our sincere thanks to Sharon Harder and Beth Noyce for their thorough presentation and for these detailed answers!

UPDATED 10/05/2016

continues to have a prognosis of six months or less if the terminal illness proceeds as expected. This is a good question to ask your Medicare Administrative Contractor (MAC)––about how the physician should show clear clinical evidence that the ESRD is not related to the terminal prognosis.

9. Must each IDG note discuss all the diagnosis for the patient?Answer: The Interpretive Guidelines of COP §418.54(d) State Operations Manual Chapter 9 state:

Hospices are free to choose their own method for documenting updates to the assessment. The hospice should evaluate and document the patient’s response to the care, treatment and services provided, and progress toward desired outcome... easily identified in the clinical record.

Hospices are required to update the comprehensive assessment as frequently as the condition of the patient requires, which may be more frequently than every 15 days ... Hospices are not required to complete, in full, those documents that they identified as comprising their comprehensive assessment every 15 days, although hospices are free to do so if they so choose. They are required to identify and document if there were no changes in the patient/family condition or needs.

10. How much lag time might there be with diagnosis claims code rejection? Is it faulty reasoning to assume that if the codes are accepted, all is good?Answer: Just because a claim is initially paid doesn’t mean that it won’t ever be subjected to a post-payment medical review. When that happens and the coding is found to be in error, payment could be recouped. For example, if the claim shows a terminal diagnosis, or a set of diagnoses not supported by the documentation in the record, there could be repayment exposure for the claim.

11. If we are listing all the diagnoses, will that force the hospice to pay for all the medications?Answer: The primary terminal diagnosis must be listed together with all related conditions related to the patient’s terminal prognosis. And, the hospice will be obligated to pay for the patient’s medications

related to those conditions. The hospice’s obligations do not change with its decision to code only some of the applicable, related diagnoses.

12. There seems to be confusion among hospice providers about when you can use the Alzheimer’s diagnosis for dementia. Are there a lot of hospices that use that diagnosis without a definitive MRI or scan demonstrating that the patient has Alzheimer’s? I think much of the dementia we see is a combination of multiple factors. Answer: ICD-10 diagnosis coding guidelines say that the physician’s diagnostic statement is enough evidence for a coder to list the diagnosis codes for Alzheimer’s dementia (etiology + manifestation) as valid diagnoses for the patient. No diagnostic testing or lab values are required in the patient record in addition to that. However, the patient must still meet qualifying criteria showing the six-months or shorter prognosis to be eligible to elect the hospice benefit.

In our reviews, we see many records without reference in the H&P to a definitive positive diagnosis based on an MRI but with a diagnosis of Alzheimer’s disease. Coverage for a patient with a primary terminal diagnosis of Alzheimer’s will be dependent on a number of factors; for example, the patient’s FAST score and co-morbid conditions. We encourage you to refer to the Local Coverage Determination (LCD) used by your MAC to evaluate Alzheimer’s patients in terms of their appropriateness for hospice care. For example, Palmetto’s LCD relates to Alzheimer’s as well as about nine other, related diagnoses for coverage determination. The NGS LCD on Determining Terminal Status has specific criteria for Alzheimer’s or other dementia diagnoses such as the presence of aspiration pneumonia, sepsis, stage three or four pressure ulcers, or kidney infections within the last 12 months. The CGS LCD has no specific dementia guidelines and offers general clinical status and non-disease specific guidelines.

13. Should hospice be paying for insulin if diabetes is unrelated to the terminal diagnosis? Answer: Patients are able to obtain coverage through Part D for medications to treat illnesses that are unrelated to the terminal prognosis. If any illness is unrelated to the terminal prognosis, the hospice physician must document clear clinical evidence

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of why any medically necessary treatments the patient receives outside of the hospice benefit are unrelated to the terminal prognosis. To facilitate that process, CMS offers a Part D Prior Authorization Form at https://www.cms.gov/Medicare/Prescription-Dr ug -Cove rage/P resc r ip t i onDr ugCovCont ra /Downloads/Instruction-and-Form-for-Hospice-and-Medicare-Part-D.pdf.

14. What would be considered normal vs. a highpercentage of live discharges?Answer: Access the hospice PEPPER for youragency to see how your live discharge ratecompares with those of other agencies in yourown state, MAC region, and the nation. When yourdischarge rate is considered high by analytics alsoused by CMS, your agency’s report will show itin red and as being at risk of further scrutiny byregulatory entities.

The Journal of Palliative Medicine in 2014 (Volume 7, Number 10 2014) suggested that the live discharge rate, nationwide is 20% (one in five patients). In January 2016, MedPAC reported that it had engaged Abt Associates to conduct a study through which it found that the median live discharge rate is 18.3%. Generally, a hospice should be well below a 15% threshold of live discharges. We would suggest that if the hospice exceeds that threshold for live discharges, it could be indicative of an issue with the admission criteria being used by the hospice and an area in which to focus compliance improvement efforts.

15. What are “too few” end-of-life visits? What isthe number we are looking for?Answer: There is no magic number of end-of-lifevisits; however, CMS is concerned that there aretoo many hospice patients without skilled visitsduring the last days of life which may suggest thatinter-disciplinary teams are not regularly monitoringchanges in patients’ conditions and increasing visitfrequencies during periods of decline. Thus, thefocus should be on determining, as accurately aspossible, when a patient is declining and adjustingvisit frequencies to ensure comfort and palliation ofsymptoms and distress.

RETRACTED: A hint of what CMS expects appears in the service intensity add-on (SIA), awarded

when combined, in-person registered nursing and social work visit hours equal eight or more hours for a routine home care hospice patient. Also, CMS continues to scrutinize, visits when death is imminent. Hospice Compare goes live in 2017, and will report which agencies’ patients receive at least one RN, NP, physician or PA visit in the last three days of life, and at least two LPN /LVN and/or Aide visits during the last seven days of life.

CORRECTED: A hint of what CMS expects appears in the service intensity add-on (SIA) payment awarded for in-person registered nursing (RN) and medical social work (MSW) services provided on routine home care days during the last seven days of life. The SIA pays the continuous home care rate for all RN and MSW combined visit time, up to four hours each day. Also, CMS continues to scrutinize visits when death is imminent. Hospice Compare goes live in 2017, and will report which agencies’ patients receive at least one RN, NP, physician or PA visit in the last three days of life, and at least two visits from MSWs, chaplains or spiritual counselors, licensed practical nurse, or hospice aides in the last 7 days of life.

16. When multiple diagnoses are listed as relatedconditions, if a patient goes for a treatment relatedto one of the related condition, how does Medicareconsider this for payment? Will they decline suchpayment?Answer: Generally speaking, if a patient seeksand receives treatment from a provider otherthan the hospice for a condition related to his/herterminal condition, Medicare will deny the claimfor reimbursement while the patient’s election ofhospice benefits is continuing. Chapter 11 of theClaims Processing Manual specifically notes that“where the service is related to the hospice patient’sterminal illness but was furnished by someoneother than the designated attending physician [ora physician substituting for the attending physician]the physician or other provider must look to thehospice for payment.”

Please keep in mind that CMS expects hospices to provide “virtually all care” for hospice patients, and that conditions unrelated to the terminal prognosis are rare. Note that the most current CMS literature now defines related conditions as those related to

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the terminal prognosis, no longer just those related to the terminal illness.

17. Are there any changes to the Face-to-Face requirement in the 2017 Final Rule?Answer: No. Face-to-Face Encounter requirements remain unchanged.

18. CMS says the cap year ends on 9/30/16, this year, instead of 10/31/16 like last year?Answer: For 2016, if the hospice calculates the cap based on the Streamlined Method, the patient count will be for the period from 9/28/15 through 9/27/16. The measure of payments will be for the period from 11/1/15 through 10/31/16. Next year – for the 2017 cap calculation – the patient count period will be from 9/28/16 through 9/30/17 with the transitional payment measurement period beginning on 11/1/16 and ending on 9/30/17.

If the hospice uses the Proportional Method, the measurement period will be from 11/1/15 through 10/31/16. Next year – for the 2017 cap calculation using the Proportional Method – the measurement period will transition, starting on 11/1/16 and end on 9/30/17.

19. If an agency is noncompliant in more than one area of reporting––for example, timely Notice of Election (NOE) filing and CAHPS submission––is it only one 2% penalty or is there a 2% reduction penalty for each area of noncompliance?Answer: If the agency is noncompliant relative to the timeliness of its NOE filings, the penalty is that the hospice is liable for the care provided during the days up to the point that the NOE is filed. This has nothing to do with the 2% reimbursement penalty for failure to timely report quality information.

20. Can you use GIP for IV hydration?Answer: General Inpatient Care must be reserved for patients whose medical condition requires an inpatient stay to address uncontrolled pain or acute symptom management that cannot be adequately controlled in another setting. Dehydration is generally expected as a normal part of the physiological decline during a patient’s last days and GIP for IV hydration would not be appropriate in this situation. OIG reports state that about half of all recent GIP stays were not appropriate.

21. Can you share the news article you discussed in the webinar? Answer: Here is the link to the article entitled “How Tens of Thousands of Patients Who Weren’t Actually Dying Wound Up on Hospice Care.” https : / /www.washingtonpost .com/news/wonk/wp/2016/09/15/how-tens-of-thousands-of-patients-who-werent-actually-dying-wound-up-on-hospice-care/

22. What length of stay would raise a red flag?Answer: There is no absolute magic number in terms of the patient’s length of stay; however, once the third benefit period starts, the Face-to-Face Encounter should be particularly focused on the patient’s continuing appropriateness for hospice services relative to his/her prognosis and the documentation in the record must be clear and convincing as to an expectation of less than six months of life if the disease process takes its normal course.

One helpful indicator would be your agency’s rate compared to others’ rates in your state, MAC jurisdiction, and in the nation, found in the hospice PEPPERs.

23. If the hospice physician states in his/her Certification of Terminal Illness (CTI) that conditions are unrelated, currently stable and not life-threatening, is it ok not to code this condition?Answer: Since October 1, 2015, hospices must assign ICD-10 diagnosis codes to ALL hospice patient conditions, whether related or unrelated to the terminal prognosis, and sequence them in the hospice Plan of Care (POC) and hospice claim in the order of their relevance to the POC. The ICD-10 diagnosis list on the claim and POC must match. Hospices do not avoid responsibility to treat and cover all conditions related to the terminal condition by omitting conditions from the POC and claim. CMS has stated repeatedly that conditions unrelated to the terminal prognosis (notice the change – not only terminal illness) are rare.

24. My understanding is that electronic NOE does not require the attending physician, but consents signed by the patient/rep do require it. Could clarify the signatures needed for an electronic NOE and the signed NOE?Answer: Let me clarify. In the example given, I was referring to the NOE attending physician entry that

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was on both the paper form and the electronic NOE. The electronic NOE will never absolutely require an entry in the “Attending Physician” field because the patient is not required to identify an attending physician.

Having said that, the Medicare Claims Processing Manual in Chapter 11 states that, “The reporting requirement... establishes that the hospice enters the NPI and name of the attending physician designated by the patient at the time of election as having the most significant role in the determination and delivery of the patient’s medical care.” This establishes the need for the hospice to identify the patient’s attending physician (if there is one) on the NOE that it files on behalf of the patient.In the meantime, when there is a mismatch between the physician listed on the patient’s NOE and/or the filed NOE and one or more signatures attributed to an attending physician elsewhere in the record for the initial cert period, the result would be a payment denial upon review. The same would be true if the correct attending physician’s signature was missing on a document that requires it, such as the initial CTI.

By way of the example that I was making, if the physician on the NOE is John Jones and Nancy Smith signed both the initial CTI and Plan of Care as the attending, the result in a medical review would be denial of the claim for the fatal error that arises when the designated attending has not signed specific documents, as required, prior to billing.

Moreover, in the case of an ADR, the hospice would be required to submit the paper form signed by the patient and there would be an expectation on the part of a reviewer that the entry on that form would match what is filed with the electronic NOE and the identity of the physician signing any initial election documentation such as the CTI.

25. What if a patient changes his or her attending physician during hospice care? Do we need to fill out another NOE with the new physician listed?Answer: There is no need for a new NOE as that document relates specifically to the election of benefits and not the patient’s choice of a physician. The change must be documented in the medical record with a signed statement from the patient or his/her representative. The text from the Medicare

Policy Manual, as changed in 2015, is as follows:“If a patient (or representative) wants to change his or her designated attending physician, he or she must follow a procedure similar to that which currently exists for changing the designated hospice. Specifically, the patient (or representative) must file a signed statement with the hospice that identifies the new attending physician in enough detail so that it is clear which physician or NP was designated as the new attending physician. This information should include, but is not limited to, the attending physician’s full name, office address, NPI number, or any other detailed information to clearly identify the attending physician. The statement must include the date the change is to be effective, the date that the statement is signed, and the patient’s (or representative’s) signature, along with an acknowledgement that this change in the attending physician is the patient’s (or representative’s) choice. The effective date of the change in attending physician cannot be earlier than the date the statement is signed.”

26. You said both physicians must sign off on the CTI and the POC. Can you show us where it is written that the POC must be signed by the attending physician before billing?Answer: Both physicians must sign off on the initial Certification of Terminal Illness. Chapter 9 of the Medicare Policy Manual notes the following at 20.1 Timing and Content of Certification:

“For the first 90-day period of hospice coverage, the hospice must obtain, no later than 2 calendar days after hospice care is initiated, (that is, by the end of the third day), oral or written certification of the terminal illness by the medical director of the hospice or the physician member of the hospice IDG, and the individual’s attending physician if the individual has an attending physician.”

Both physicians should sign the initial Plan of Care and at least one must sign it. If the attending physician is an NP who signs the initial Plan of Care, the Medical Director of the hospice must also sign it.

Here is the six-part rationale for the argument:Part 1) Section 20.1 of the policy manual states the

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following:“The attending physician is a doctor of medicine or osteopathy who is legally authorized to practice medicine or surgery by the state in which he or she performs that function, or a nurse practitioner, 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.”

Part 2) In the same chapter, at 40, the Medicare Policy Manual notes the following with respect to the Plan of Care:

“A plan of care must be established and periodically reviewed by the attending physician, the medical director, and the interdisciplinary group of the hospice program.”

The policy manual goes on at 40 to state that care plan updates must be done “in consultation” with the attending physician.

Part 3) Chapter 9 of the policy manual is actually silent on the issue of the signature; however, the Plan of Care is an order for services and, as such, it must be signed per the program integrity guidance found in Chapter 3 of the Program Integrity Manual which notes the following at 3.3.2.4:

“For medical review purposes, Medicare requires that services provided/ordered be authenticated by the author. The method used shall be a handwritten or electronic signature. Stamped signatures are not acceptable.”

Exception 3 goes on to state that if the relevant CMS manual is silent on whether the signature needs to be present and the signature is missing, the medical reviewer will follow the guidelines in Chapter 3 as to the sufficiency of the document.

Part 4) That brings us to the question of who must actually “author” the initial Plan of Care. What we know is that the attending must, by virtue of Medicare policy, be involved in creating and approving the initial Plan of Care as he/she is the individual with the most significant role in the determination and delivery of services.

Thus, there is a need for the attending to “review”

the Plan of Care rather than simply be “consulted” as to its contents. And, the substantiation of that review/approval is borne out by his/her signature on the document.

Part 5) As a result, for the initial Plan of Care, based on the combination of requirements found in Chapter 9 of the Medicare Policy Manual and Chapter 3 of the Program Integrity Manual, a signature should be obtained from the attending physician on the initial Plan of Care. For changes to the initial Plan of Care made by the IDG “in consultation” with the attending physician, his/her signature would not be required, but the hospice physician would be required to sign off on those orders to update or change services.

Part 6) We also note that the hospice is obligated to identify the “ordering/referring physician” on the claim and, as the theory goes, the underlying physician orders, including the Plan of Care, must be substantiated with a signature (and date of signature) in the record.

27. How do you authenticate/prove verbal receipt for CTI?Answer: The clinician receiving the verbal certification attests as to date on which the certification(s) is received and from whom. He/she then signs and dates the attestation. Remember that if the verbal certification relates to the initial certification period, the attestation must include both physicians to be valid for purposes of coverage between the date of the patient’s election of services and the date upon which the signed, dated certifications were finally received from the physicians.

28. My previous understanding was that CMS had clearly stated that the hospice POC did not require a physician signature. Can you tell us where CMS has stated that it does require a physician signature? Answer: You may be referring to the contents of the Medicare Policy Manual at Chapter 9 which is, in fact, silent on the signature requirements for the Plan of Care. Indeed, Chapter 9 refers to the fact that the Plan of Care must be developed based on the hospice’s assessment of the patient and in conjunction with the attending physician, if any. However, Chapter 3 of the Medicare Program Integrity Manual establishes the signature

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requirement, stating that, “for medical review purposes, Medicare requires that services provided/ordered be authenticated by the author. The method used shall be a handwritten or electronic signature.” The program integrity guidance goes on to note that, for medical review purposes, if the relevant regulation in a CMS manual is silent on whether a signature needs to be present, reviewers must follow the program integrity guidelines in Chapter 3 to qualify the document in which services are ordered. Thus, CMS has definitely stated that Plans of Care must be signed by the physician ‘author(s)’ of the plan.

29. Are both signatures for the Plan of Care required only for the admission POC? Is it okay for only the medical director to sign the recert POC? Answer: Generally speaking, Plans of Care must be signed by “the author” who is able to order the services. Because hospice regulations require that the attending participate in the development of the initial Plan of Care, he/she should attest to that fact via a signature on the document. For updates to the care plan, the rules require consultation with the attending, but stop short of indicating that he/she must be actively involved in creating them. Thus, for recertification periods, only the hospice physician needs to sign the care plan updates.

One additional note, here. The regulations do not expressly require that each recertification period commence with a completely new Plan of Care. This is because of the requirement that the inter-disciplinary team must update the Plan of Care at least every 15 days. So, during our reviews we see hospices handling the issue of the Plan of Care in two different ways. Many, in conjunction with the subsequent certification period, create an entirely new Plan of Care that serves as the baseline for that cert period, with the IDT updating it every two weeks. Others simply rely on the continuous cycle of IDT updates for the entirety of the patient’s election period and this approach is also permissible under a technical reading of the rules.

30. Doesn’t the Hospice Code of Federal Regulations (CFR) state that the signature can be of the medical director or physician member of the IDG and the attending physician?Answer: If the patient identifies an attending

physician upon election of hospice benefits, the initial Certification of Terminal Illness must be signed by both the patient’s attending physician and the hospice medical director. Subsequent CTIs need only be signed by the medical director.

Further, the State Operations Manual §418.3 Definitions says:

Physician means an individual who meets the qualifications and conditions as defined in Section 1861(r) of the Act and implemented at §410.20 of this chapter.

Physician designee means a doctor of medicine or osteopathy designated by the hospice who assumes the same responsibilities and obligations as the medical director when the medical director is not available.

31. How do emergency preparedness requirements differ between an inpatient hospice facility and a community-based hospice agency?Answer: One major difference between the requirements is that inpatient facilities are obligated under the rule to provide information as to their occupancy and patient evacuation needs to the authority having jurisdiction in the case of an emergency. This requirement does not apply for home-based services.

Home-based hospices must also have follow-up procedures in the event services are interrupted during or due to an emergency. Home-based hospices must inform the authorities of any on-duty staff or patients that they are unable to contact both during and after the emergency.

32. Could you please repeat the types of disasters that will require emergency planning? I understand the importance of planning, but it seems nearly impossible to have a written plan for every type of disaster possible. Answer: An emergency is virtually any situation that can have the effect of disrupting patient services and can be a long-term event or something that is relatively short in duration. Emergencies, as a result, can include weather events such as tornadoes, hurricanes or flooding after excessive rain, power outages, cyber attacks, terrorist activities, fires, etc. The key, in order to be compliant with the rule, will

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be to conduct an agency-specific risk assessment, have emergency policies and procedures in place, a communication plan (and means for communicating through an emergency network), and a training and testing plan to ensure that the agency’s procedures will be effective.

33. A financial question. Last year, the FISS system was not ready to accept new CBSA codes for our region. Will they be ready for the October 2016 claims? We had to go back to change codes and I would like to avoid cash flow issues. Answer: This is a good question but not one that we can definitively answer. In 2015, we believe that the issue related to the calculations of the blended rates. This year, the wage index reverts to the standard CBSAs so we are hoping that the claim processing will be a little smoother. For the best and most up-to-date information, we suggest directing the question to your MAC.

34. Will there be a clearly defined rule for the amount of time a patient can get respite services?Answer: A patient can receive inpatient respite services for up to five consecutive days. Respite care that extends beyond five days would not be reimbursable at the inpatient respite rate and would be paid at the routine home care rate.

35. Is there a set percentage that a hospice must not exceed for patients on service more than 60 days?Answer: There is no set percentage of patients that should continue on service for more than a specified number of days. The point is that hospices with exceptionally high average lengths of stay are more likely to have repayment obligations.

36. If a patient is admitted to hospice with a feeding tube, is the hospice responsible for paying for the feedings? If this same patient needs to go into the hospital for a G-tube replacement in a hospice-contracted hospital, is the hospice responsible for paying for the G-tube replacement?

Answer: If the patient with enteral feedings elects hospice care and the formula is unrelated to the terminal diagnosis or terminal prognosis-related condition(s) the hospice would not be expected to pay for it. The same would apply for the G-tube replacement under that set of circumstances.

The FY 2017 Hospice Final Rule states:In the December 16, 1983 Hospice final rule (48 FR 56010), regarding what is related versus unrelated to the terminal illness, we stated: “...we believe that the unique physical condition of each terminally ill individual makes it necessary for these decisions to be made on a case by case basis. It is our general view that hospices are required to provide virtually all the care that is needed by terminally ill patients.” Therefore, unless there is clear evidence that a condition is unrelated to the terminal prognosis, all conditions are considered to be related to the terminal prognosis and the responsibility of the hospice to address and treat.

For example, if a hospice patient has Esophageal Cancer which has necessitated the need for tube feedings (although we concede that this would probably not be a G tube) the feedings are related and would be covered by the hospice.

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The software that powers post-acute care

about the authorsSharon S. Harder has over three decades of executive management experience in the healthcare industry. As President of C3 Advisors, LLC Sharon engages with clients to develop and implement the strategic vision required to improve their profitability and competitive position in the rapidly transforming healthcare market place. Learn more at C3Advisors.com.

Beth Noyce, RN, BSJMC, HCS-H, HCS-D, COS-C provides consulting, education, and auditing services to hospice and home health agencies, and affordable instant in-services at noyceconsulting.com. She has served as a MAC medical reviewer and has written extensively for DecisionHealth’s guides, manuals and courses.