by editor | Oct 20, 2022 | Compliance and Regulatory - Directors, Reports
What are hospice volunteers?
The hospice movement was started by volunteers and there are currently more than 460,000 hospice volunteers nationwide.
To retain the volunteer-based essence of hospice, one of the Medicare conditions of participation requires that hospices incorporate volunteer services into their daily patient care and operations routine.
Is there a requirement on the number of hospice volunteer hours?
Medicare requires that volunteer must provide services that equal at least 5% of the total patient care hours of all paid hospice employees and contract staff. Read more about this requirement here: What is a hospice’s volunteer requirement?
How is the Medicare 5% requirement calculated?
The percentage of volunteer time is calculated in three steps:
- Step 1: Calculate the sum of volunteer direct care patient hours plus volunteer bereavement support patient hours plus volunteer administrative hours. See What is a hospice’s volunteer requirement? for clarification on these various types of volunteer hours and activities as well as clarification on what volunteer activities may be applied for use in this calculation.
- Step 2: Calculate the sum of employee direct care patient hours plus contractor direct care patient hours
- Step 3: Divide the number in Step 1 by the number in Step 2 and multiply by 100. The result is the percentage of volunteer hours
What activities performed by hospice employees or contractors are included?
Similar to the limitations placed on volunteer activities that may be included for the purposed of this Medicare match calculation, not all activities performed by a hospice’s employees or contractors are included in Step 2.
Hours for the following staff are included in the calculation (though others may be included as well): nurse, social worker, physician, physical therapist, hospice aide, chaplain, bereavement counselor
- All direct care activities are included in the calculation
- Telephone calls to patients, families, or surviving family members are included
- Staff education time is not included
- IDG time is not included
Where can you get more information?
Read more about hospice volunteer requirements: NHPCO Hospice Volunteer FAQ
by editor | Oct 20, 2022 | Compliance and Regulatory - Directors, Reports, Rules and Regulations - Nurses
Volunteers are an essential components of hospice. The hospice movement was started by volunteers. There are currently more than 460,000 hospice volunteers nationwide. Volunteers provide administrative support or direct patient care services.
Are hospices required to have volunteers?
Use of volunteers is a Medicare condition of participation. Medicare requires the use of hospice volunteers for any Medicare certified hospice. Volunteers must be used in day to day administrative tasks that support direct patient care activities and/or in direct patient care roles.
For each hospice agency, volunteer hours must equal 5% of total patient care hours for all paid hospice agency employees and contractors. A hospice must maintain records of the number of hours worked by volunteers as well as the types of activities performed and whether these activities were administrative or patient care.
The hospice volunteers must perform their activities under the supervision of a designated hospice employee.
Are there other volunteer-related requirements?
There are additional training and documentation requirements that a hospice agency must meet, relating to hospice volunteers:
- A hospice must provide orientation and training for its hospice volunteers and this training must documented
- Efforts to recruit volunteers on an ongoing basis must be documented
- Cost savings achieved through the use of volunteers must be documented. The documentation must include the volunteer’s position, the time spent by the volunteer, and the estimated dollars that would have been spent by the hospice had this position been filled by a paid hospice employee
What direct patient care activites are performed by a volunteer?
Volunteers travel to the location where the patient currently resides – such as the patient’s home, a nursing home, or an assisted living facility – and work directly with patients, caregivers, and families. These volunteers are considered direct care volunteers. Examples of direct care activities include:
- Performing light household chores
- Cooking meals
- Provide transportation for patients or their families
- Provide companionship to the patient
- Providing respite so that family caregivers can take a break
- Using some special skills that the volunteer has such as giving a manicure, giving a haircut, playing a musical instrument, doing an art project with the patient, and the like
- Travel time to the patient’s home may also be included in volunteer hours, if travel time is also used in the calculation of hospice employee hours
- Time a volunteer
What indirect care activities are performed by a volunteer?
Volunteers can also have an impact without directly interacting with patients. For example, they can prepare items that are delivered to patients, they can advocate for hospice patients in the community, or they can go to volunteer health fairs. Indirect care hospice volunteers can also assist the hospice agency with administrative and general office tasks. Examples of indirect care activities include:
- Assisting with preparing mailings for community outreach
- Assisting with data entry, filing, copying, or other clerical duties
- Answering phone calls,
- Preparing blankets to be delivered to hospice patients
- Helping setup for community events
- Helping with grief support groups
What activities may be included in the calculation of volunteer time?
There activities that may be included in total hospice volunteer hours are varied. For example:
- Time that the volunteer is performing the actual tasks (such as assisting with mailings, data entry, light housekeeping, etc.)
- Telephone calls to hospice patients, their family members, caregivers, or bereaved family members
- Travel time to patient homes, if this travel time is included in the calculation of hours for hospice employees
- Time spent receiving orientation to a specific patient
- Time spent in training to perform specific tasks
What activities may not be included in the calculation of volunteer time?
Recall that volunteers must be used in day to day administrative and or direct care patient roles. So the following are examples of activities that would not be included in the calculation of total volunteer hours:
- Flower arranging
- Working in a thrift shop
- General volunteer training that is not specific to a patient or to an administrative task
- Participation in the agency’s governing board
Where can you find out more?
by editor | Oct 18, 2022 | Billing, Billing - General, Compliance and Regulatory - Directors, Medical Records, Rules and Regulations - Nurses
What is a hospice election statement?
A hospice election statement is a condition of payment under Medicare. For a patient to be eligible to receive hospice services under the Medicare benefit, the patient or the patient’s authorized representative must elect hospice care by signing a hospice election statement. While Medicare provides a model of this form, each hospice agency is free to design their own hospice election form. However, there are some required elements, as specified by Medicare. To find out more details about the hospice election statement, read more at our blog post here: What is the Hospice Election Statement requirement?
Why is the hospice election statement important?
An invalid hospice election statement can impact payment for the entire patient hospice stay. There has been a recent rise in denials related to the election form. As such, it is important for hospice agencies to ensure that all required elements are present on the form and that the forms are completed accurately.
What are are tips for avoiding common hospice election form denials?
- Tip 1: Use the model election form provided by CMS or stick to something very close to it. This will ensure that no critical elements are missed. CMS has provided a model hospice election form. Hospice agencies are not required to use this model form; they may design their own election form.
- Tip 2: Focus on the purpose of the document and stick with the required elements, Over the years, hospices have had a tendency to add to their election forms so that it has been moving away from its original legal intent. While it is good to provide patients with additional information, the election form may not be the appropriate place to provide this information. By adding information to the election statement, there is a risk that upon audit contractors may find fault with aspects of the document that are not part of Medicare’s required elements of the election statement. In other situations, contractors missed the election statement since it was buried in a such a long document.
- Tip 3: build in redundancy in the elements of the elements of the hospice election statement. Use the admission material to build in redundancy of the required elements of the hospice election statement. That is, the required elements can be included in the election statement but some of the election statements which, for example, are acknowledgement statements, can be included in other admission material that is provided to the patient on admission. This could be helpful to defend potential claim denials or invalid denials in case of audit.
- Tip 4: Reduce the possibility of errors in completing the forms, by stressing the importance of the forms, creating standardized processes, and leveraging technology. Reduce human error by ensuring that the individuals responsible for completing the documents understand their importance. Human error is the biggest problem with properly completing the hospice election statement form. Create processes to double check the forms – in real time. Leverage technology, where possible, to eliminate the possibility of errors or to detect errors.
Where can you find more information?
by editor | Oct 18, 2022 | Billing, Billing - General, Compliance and Regulatory - Directors, Hospice 101 - Aides, Hospice 101 - Chaplain, Hospice 101 - Office Team, Hospice 101 - Social Workers, Rules and Regulations - Chaplains, Rules and Regulations - Nurses, Rules and Regulations - Social Workers
To receive hospice services under the Medicare benefit, a patient or his authorized representative must elect hospice care.
If the patient or authorized representative elects to receive hospice care, the patient must file an election statement with a specific hospice agency. The election statement serves to indicate that the patient is choosing hospice care.
The election statement and the election statement addendum are conditions for payment.
What is the structure of a hospice election form?
Every hospice agency can design and create their own hospice election statement form although Medicare has published a model form that can be used by hospice agencies Model Hospice Election Statement. The election statement must include all of the following elements:
- Name of hospice agency that will be providing the services
- Acknowledge that nature of hospice services have been explained to the patient including, in particular, the palliative rather than curative nature of care
- Acknowledge patient understands that by electing hospice care, some Medicare services are waived
- For hospice elections beginning on or after October 1, 2020, a statement that although it would be rare, there could be some necessary items, drugs, or services that may not be covered by hospice because these items are deemed to be unrelated to the terminal illness or related conditions
- The effective date of the election. This may be the first day of hospice care of a later day. But it cannot be a date that precedes the date that the election statement was signed by the patient or their authorized representative.
- The individual who is serving as the patient’s attending physician, if any.
- Acknowledgement that the identified attending physician was the choice of the patient or authorized representative
- Signature of patient or authorized representative
There are some additional requirements for the election statements for elections beginning dated October 1, 2020 or later. These election statements must also include :
- Information on patient cost sharing for hospice services
- Notification of the patient or authorized representative right to receive an addendum to the election statement. The addendum is only required to be furnished to beneficiaries, their authorized representatives, non-hospice providers, or Medicare contractors who request this information. This addendum includes a list and rationale for the items, drugs, or services that are not covered by hospice services because the hospice has deemed these to be unrelated to the terminal illness and related conditions.
- Information on the Beneficiary and Family Centered Care Quality Improvement Organization (Beneficiary and Family Centered Care (BFCC) ), including that immediate advocacy is available through this organization if the patient disagrees with the hospice’s determination regarding non-covered services
Right to Request Patient Notification of Non-Covered Items, Services, And Drugs
At any time, a patient may request, in writing, the Patient Notification of Hospice Non-Covered Items, Services, and Drugs. addendum to the election statement.
The hospice agency must provide the notification within five days, if this request is made on the start of care date.
If the request is made during the course of hospice care, the hospice agency must provide the requested notification within 72 hours.
If the patient (or authorized representative) requests the addendum at the start of care but dies with five days, the hospice is deemed to have met its requirement and is not required to provide the addendum.
When would a hospice update the addendum?
The addendum lists the patient’s diagnoses and conditions that are present upon hospice admission and the items, services, and drugs that are not covered by the hospice because they are deemed to be unrelated to the terminal illness and related conditions.
During the course of hospice care, the addendum may require update, for example, if the patient’s plan of care is updated.
Changes to the addendum will need to be signed by the patient or his authorized representative and stored in the patient’s medical record with the hospice agency.
Where can you find more information on the election statement
by editor | Sep 29, 2022 | Billing, Billing - General, Compliance and Regulatory - Directors, Financials, Rules and Regulations - Office Team
What is Medicare credit balance?
A Medicare credit balance represents a Medicare overpayment to a provider due to patient billing error or claims processing error that must be refunded to Medicare. The report is referred to as a Credit Balance Report because when a provider receives excess payment for a claim that was submitted, this is typically reflected in the provider’s accounting records (i.e., in the patient account receivable) as a “credit.”
What instances may give rise to a credit balance?
Different situations may give rise to a Medicare overpayment. For example:
- Paid twice by Medicare or may be paid by Medicare and by another insurer for the same service
- Incorrect calculation of patient deductible or patient coinsurance amount
- Paid for non-covered services
- Billed at incorrect daily rate
Which hospice agencies must file a Credit Balance Report?
If a hospice provider has more than one provider number, a separate report must be submitted for each provider number. Providers who have a low utilization (i.e., determined by the intermediary that they should file a low utilization Medicare cost report) or who file less than 25 Medicare claims per year are not required to file a Medicare Credit Balance Report.
What does a credit Balance Report Consist of?
The Credit Balance Report consists of two pages. The first page is a Detail Page, where the hospice provider enters information about each credit balance, on a claim by claim basis. Once a claim has been reported on one Credit Balance Report it should not be reported again on a subsequent Credit Balance report. The second page is a Certification Page. All providers must complete the Certification Page. The Detail Page is only required if the provider has credit balances to report.
The Detail Page
On this page, the provider must include detailed information about each Medicare claim with a credit balance, explanation why the credit balance arose, and indicate whether the credit balance is being repaid with the filing of the report.
The Certification Page
The second page of the Credit Balance Report is a certification page. Facilities that do not have any credit balances in a quarter are only required to submit the signed certification page. There are key areas of this page.
- The first area serves as a reminder that there is a requirement to file a Credit Balance Report and failure to file this report will result in suspension of Medicare payments. Further, any misrepresentations may lead to fines and further penalties
- The second area requires an officer or administrator of the hospice agency to sign a certification that that Credit Balance Report is true and accurate
- The third area requires a selection from one of three choices: (i) provider qualifies as Low Utilization Provider (ii) Detail Page included with Report (iii) no credit balances to report
When is the report due?
A hospice provider must assess any Medicare credit balances on a quarterly basis and must report any identified Medicare credit balances within 30 days of the end of each calendar quarter. The Medicare Credit Balance Report due dates are as follows:
| Quarter Ending |
Due Date |
| March 31 |
April 30 |
| June 30 |
July 30 |
| September 30 |
October 30 |
| December 31 |
January 30 |
What happens if a provider fails to submit a Credit Balance Report?
Failure to submit a Credit Balance Report by the 15th calendar day after the report due date will result in a Suspension Warning letter. If the completed report is not received within 15 calendar days from issuance of the letter, Medicare payments to the provider are suspended under a completed letter is received, accepted, and processed.
Where can you find a Credit Balance Report form?
The Credit Balance Report that must be completed and submitted is Form CMS-838, which can be found here: Medicare Credit Balance Form (pdf)
by editor | Sep 20, 2022 | Billing, Billing - General, Compliance and Regulatory - Directors, Financials, Intake, Notice of Election, Rules and Regulations - Nurses, Rules and Regulations - Office Team
