Hospice Conference Tips: Key Billing Issues You Should Be Wary of

If direct care by physicians and nurse practitioners is contemplated, then it's important to explore becoming a Part B provider or entering into a joint venture with a physician group. And when you're doing that, it's important first to evaluate corporate practice of medicine to determine whether you are permitted to employ a physician or whether you're going to have to contract with physicians.  Read this expert information provided by our speaker in a hospice conference and snip through the regulatory red tape and position your hospice as a leading provider.

And then once again, if you're an NHPCO member, their website contains a state by state bit of information on corporate practice of medicine. Again, you'll need to evaluate state fee splitting laws if you're to set up a Part B clinic. And then you need to enroll. And the checklist includes a link to the enrollment form.

It's important - if you're thinking about enrolling, you enroll to your Part B carrier. And that’s different than your RHHIs. So, it's Part B, not Part A. But sometimes those Part B carriers get very confused by this. And they think that there’s a hospice applying to the wrong place. And they’ll tell you, “You can't be a Part B provider. You're a hospice.”

Well, the thing is you're maybe a hospice but you're doing something that’s not hospice. You're setting up a Part B clinic. And it's perfectly permissible. As our expert mentioned in the hospice conference, sometimes it helps if you actually use a different corporation to set up your Part B clinic.

There are a number of healthcare audits going on within palliative care Part B programs. And it just helps to keep things as absolutely separate as possible between the hospice and the Part B palliative care program for non-hospice patients. So if you're going to do this, we would strongly suggest that you think about actually setting up a new corporation to be the Part B provider.

Billings to patients have to be based on fair market value. And the federal law prohibits inducements to Medicare beneficiaries. So now, in terms of billing patients, if you're going to reduce fees, then it's very important to have a sliding fee scale. And that should be documented and consistently followed.

There was a special advisory bulleting back in 2002 where the OIG talked about gift and other inducements to beneficiaries. And they made it clear that gift of $10 or $50 to the same beneficiary in one year would excessive and would be considered impermissible inducement. So clearly, pre-care unless you do it based on a sliding scale charity care basis is going to be suspect.

In terms of billings to other providers, those other providers again should be billed based on fair market value. And again, this is an area that it's important to have legal counsel review. Also, it's extremely important to make sure that you are billing and coding correctly. We’ve seen some hospices now that have not understood Part B billing and have gotten themselves into some trouble inadvertently or they have a billing agency that doesn’t even really understand Part B either. And it's very important - if you're going to embark on this course, to make sure that you get good advice about healthcare coding and billing.

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