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These frequently asked questions have been compiled by our clinical and regulatory experts here at Briggs. If you don’t find the answer you are looking for, click here to submit a question.
Clinical Documentation
Expedited Review
Advance Beneficiary Notice (ABN)
Clinical Documentation
Q: Where can I find Conditions of Participation (CoP), the Joint Commission and Community Health Accreditation Program (CHAP) crosswalks for regulations and standards?
A: We have current CoP, the Joint Commission and CHAP crosswalks in both our Home Care and Hospice Documentation Systems. Not only do we have the crosswalks, each form in the manual also shows the applicable CoP and accreditation standards crosswalks.
Q: Do you have a form that can be used strictly for wound care?
A: Yes. Our wound care form, Stock No. 3466P, is a Wound Assessment Tool with Braden Scale.
Q: Do you have forms that can be used in a free standing hospice facility, for example shift care forms?
A: We have hospice in-patient forms including shift care forms as well as other assessments. Click here for more information.
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Expedited Review
Q: Do you have available the generic and detailed notices of Expedited Review that the Centers for Medicare and Medicaid (CMS) issued?
A: Those Expedited Review forms became mandatory July 1, 2005. They are Briggs forms, CMS-10123 and CMS-10124. Providers must still continue to use the current Hospice Advanced Beneficiary Notice (ABN), which is Briggs form CMS-R-131-G. To see a copy of the September 29 regulation revising the instructions that determine when to deliver an ABN in hospice, click here.
Q: Is there a policy for the new Expedited Review Notice?
A: Yes. For an article discussing the Expedited Review and a sample policy that can be incorporated into the operational policies you currently have, click here.
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Advance Beneficiary Notice (ABN)
Q: What is the status of the proposed revisions to the ABN?
A: On May 25th, 2007, CMS requested an additional comment period. Click here for more details in the BriggsCorp.com News Center.
Q: If a patient is being discharged home from a care center (inpatient general or inpatient respite) or taken off continuous care, would it be appropriate to issue an ABN?
A: When there is a level of care change, an ABN is not required since there is no beneficiary liability.
Q: In the situation where the patient/family want to continue the higher level of care but the hospice disagrees, would the hospice have to issue an ABN?
A: The level of care change is based upon by patient need, not patient preference. Hospices should ensure that prior to the election of benefit, individuals understand the nature of the levels of care and how they are determined.
If a patient wishes to remain in a facility, she/he may receive an ABN explaining that she/he is responsible for room and board and that the care rendered by the hospice will be a routine level of care. The room and board payment by the beneficiary should NOT be the difference in the amount paid by Medicare to the hospice for the higher level of care: they pay for room and board ONLY.
Q: If the above answer is yes, an ABN is issued, the concern is that if the notice is given at the time of decreasing the level of care services, the patient/family may feel they have the option of continuing with the higher level of care, even though the care would be considered outside of the hospice plan of care and the patient/family may have to pay for it. There are times when the patient/family decide they like the comfort of having the 24-hour care and do not want to go back to the routine home care level of care.
A: As indicated in the above question.
Q: Would it be alright for a hospice to refer a patient to the services of another provider for this additional care because the hospice does not provide private service?
A: The hospice could assist the beneficiary in finding services that Medicare does not pay for, e.g. private care, so beneficiaries and their families have the opportunity to choose among options. A Notice of Exclusion from Medicare Benefits (NEMB) could be provided.
The NEMB is not based on beneficiary liability protections established by Section 1879 of the Social Security Act but may be used to fulfill other notice requirements. NEMBs alert Medicare beneficiaries in advance that Medicare does not cover certain item(s) and/or service(s) because the item(s) or service(s) do not meet the definition of a benefit or are specifically excluded by law.
Q: If a Medicare hospice benefit patient/family wants a diagnostic test that the hospice Interdisciplinary Group (IDG) does not consider medically reasonable or necessary for providing care related to the patient’s terminal illness, should the hospice provide an ABN?
A: The hospice is responsible for all medically reasonable and necessary services pertaining to the terminal and related conditions. Diagnostic tests are included. If the medical director and/or physician member of the IDG orders the test, it is considered covered under the daily per diem rate.
It would not be appropriate to have the test ordered by a physician other than the hospice physician in order to defer payment. If there is no medical necessity and the patient/family insists, the hospice would not be liable. If the test is related to the patient’s terminal and related conditions, it will not be covered under Medicare Parts A and B. CMS believes that an ABN would not be required if these circumstances are met.
back to top
Clinical Documentation
Expedited Review
Advance Beneficiary Notice (ABN)
Clinical Documentation
Q: Where can I find Conditions of Participation (CoP), the Joint Commission and Community Health Accreditation Program (CHAP) crosswalks for regulations and standards?
A: We have current CoP, the Joint Commission and CHAP crosswalks in both our Home Care and Hospice Documentation Systems. Not only do we have the crosswalks, each form in the manual also shows the applicable CoP and accreditation standards crosswalks.
Q: Do you have a form that can be used strictly for wound care?
A: Yes. Our wound care form, Stock No. 3466P, is a Wound Assessment Tool with Braden Scale.
Q: Do you have forms that can be used in a free standing hospice facility, for example shift care forms?
A: We have hospice in-patient forms including shift care forms as well as other assessments. Click here for more information.
back to top
Expedited Review
Q: Do you have available the generic and detailed notices of Expedited Review that the Centers for Medicare and Medicaid (CMS) issued?
A: Those Expedited Review forms became mandatory July 1, 2005. They are Briggs forms, CMS-10123 and CMS-10124. Providers must still continue to use the current Hospice Advanced Beneficiary Notice (ABN), which is Briggs form CMS-R-131-G. To see a copy of the September 29 regulation revising the instructions that determine when to deliver an ABN in hospice, click here.
Q: Is there a policy for the new Expedited Review Notice?
A: Yes. For an article discussing the Expedited Review and a sample policy that can be incorporated into the operational policies you currently have, click here.
back to top
Advance Beneficiary Notice (ABN)
Q: What is the status of the proposed revisions to the ABN?
A: On May 25th, 2007, CMS requested an additional comment period. Click here for more details in the BriggsCorp.com News Center.
Q: If a patient is being discharged home from a care center (inpatient general or inpatient respite) or taken off continuous care, would it be appropriate to issue an ABN?
A: When there is a level of care change, an ABN is not required since there is no beneficiary liability.
Q: In the situation where the patient/family want to continue the higher level of care but the hospice disagrees, would the hospice have to issue an ABN?
A: The level of care change is based upon by patient need, not patient preference. Hospices should ensure that prior to the election of benefit, individuals understand the nature of the levels of care and how they are determined.
If a patient wishes to remain in a facility, she/he may receive an ABN explaining that she/he is responsible for room and board and that the care rendered by the hospice will be a routine level of care. The room and board payment by the beneficiary should NOT be the difference in the amount paid by Medicare to the hospice for the higher level of care: they pay for room and board ONLY.
Q: If the above answer is yes, an ABN is issued, the concern is that if the notice is given at the time of decreasing the level of care services, the patient/family may feel they have the option of continuing with the higher level of care, even though the care would be considered outside of the hospice plan of care and the patient/family may have to pay for it. There are times when the patient/family decide they like the comfort of having the 24-hour care and do not want to go back to the routine home care level of care.
A: As indicated in the above question.
Q: Would it be alright for a hospice to refer a patient to the services of another provider for this additional care because the hospice does not provide private service?
A: The hospice could assist the beneficiary in finding services that Medicare does not pay for, e.g. private care, so beneficiaries and their families have the opportunity to choose among options. A Notice of Exclusion from Medicare Benefits (NEMB) could be provided.
The NEMB is not based on beneficiary liability protections established by Section 1879 of the Social Security Act but may be used to fulfill other notice requirements. NEMBs alert Medicare beneficiaries in advance that Medicare does not cover certain item(s) and/or service(s) because the item(s) or service(s) do not meet the definition of a benefit or are specifically excluded by law.
Q: If a Medicare hospice benefit patient/family wants a diagnostic test that the hospice Interdisciplinary Group (IDG) does not consider medically reasonable or necessary for providing care related to the patient’s terminal illness, should the hospice provide an ABN?
A: The hospice is responsible for all medically reasonable and necessary services pertaining to the terminal and related conditions. Diagnostic tests are included. If the medical director and/or physician member of the IDG orders the test, it is considered covered under the daily per diem rate.
It would not be appropriate to have the test ordered by a physician other than the hospice physician in order to defer payment. If there is no medical necessity and the patient/family insists, the hospice would not be liable. If the test is related to the patient’s terminal and related conditions, it will not be covered under Medicare Parts A and B. CMS believes that an ABN would not be required if these circumstances are met.
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