Documenting Relatedness and Its Role in Payment-Related Scrutiny

Outline:

Objectives

Case Scenario — Mrs. OutofBreath

Question: Who is the Sicker Patient?

Case Scenario — Mrs. OutofBreath

Question: Who is the Sicker Patient?

Everyone, Put Your Hospice Hat Back On

So, Hit the Easy Button…

History of Relatedness Determination and Hospice Care

How did We Get Here? Cycle of Payment-Related Scrutiny

Cycle of Payment-Related Scrutiny

The OIG, Relatedness Determination, and Outside of Hospice Spending

CMS Statements of Relatedness

CMS Regarding Diagnosis and Coding

Medication Coverage, Part D, and PEPPER

PEPPER: Part D Claims per Beneficiary at Home

PEPPER: Part D Claims per Beneficiary in a Nursing Facility

Strategies to Relatedness Determination

Determining Relatedness to the Terminal Prognosis Process Flow

NHPCO Relatedness Process Flow

Determination of Hospice Medication Coverage

Hospice Medication Payment Responsibility

Where Quality Meets Compliance

Key Components

Documentation of Relatedness

Example: Mr. Heartbroken

Determining Relatedness to the Terminal Prognosis Process Flow

Mr. Heartbroken: Medication List

Determination of Hospice Medication Coverage

Mr. Heartbroken’s Diagnoses Are All Related to His Terminal Prognosis but Are His Medications Medically Indicated?

We Need More Information

Mr. Heartbroken’s New Med List

How to Perform a Med Review

Example Documentation of a Related Condition and Medication Not Indicated

Example Documentation of an Unrelated Condition and Medication

Deprescribing Resource

Final Word: CMS and Relatedness Determinations

Dr. Lauren Templeton is a certified hospice medical director working at a Texas hospice since 2014 and as a physician consultant with Weatherbee Resources since 2017. She has specialized in hospice and palliative medicine for more than 10 years.

In her hospice medical director role, she assists with compliance, quality improvement, and documentation review. She continues to participate in clinical care managing hospice patients in both the home care and inpatient setting. Dr. Templeton also serves as associate medical director for the Palliative Care Department at a local medical center as well as serving on the foundation board, medical executive committee, and ethics committee at the same facility.

As a Physician Consultant with Weatherbee Resources, Dr. Templeton assists hospice providers and physicians with education, coaching, and mentoring for hospice physicians, auditing physician and other clinical record documentation (e.g., thoroughness and appropriateness with regard to hospice eligibility; compliance with regulatory requirements; appropriateness with regard to coverage determinations; etc.), and record review or expert witness testimony on legal matters involving patient eligibility.

Dr. Templeton graduated from Pennsylvania State University with a Bachelor of Arts and received her doctor of osteopathy from Ohio University College of Osteopathic Medicine in 2009. She completed a residency in Internal Medicine and is board certified with the American College of Osteopathic Internists. She completed a fellowship in Hospice and Palliative Medicine at Texas Tech University and became board certified in hospice and palliative medicine in 2013. She obtained additional certification with the Hospice Medical Director Certification Board in 2018. Dr. Templeton also serves as a current member of the NHPCO Regulatory Committee.

Disclosure: Lauren Templeton, D.O., HMDC has no Relevant Financial or Non-Financial Relationship with ineligible companies to disclose.