Last year, a hospice medical director in Pennsylvania, was convicted of Medicare fraud for false certifications of the clinical eligibility of patients for hospice care. The wrongdoing involved appears to be fairly black and white. However, another more nuanced area of regulatory oversight of physicians is looming on the horizon.
Years of experience and research have demonstrated that “…people learn, and organizations change most readily when they focus on, study, and engage in dialogue about strengths, patterns of success and who they are at their best."
Through collaborative thinking, the team chooses innovative processes that are in alignment with both the strengths identified in Discovery and the imagined hopes of the future (Dream).
Every hospice physician has experienced difficulties in assessing “gray” patients. These are the ones who, at admission, do not have a principal diagnosis or terminal story that leaps out from the record, although for many of these patients, the physician is able to answer “no” to the “would you be surprised if your patient dies within the next six months” question.
- Are these patients truly terminally ill?
- Is a period of seeming stabilization sustainable?
- Should these patients be evaluated for discharge due to extended prognosis?
The Medicare Hospice Benefit has always defined the terminal illness, not as a single diagnosis, but as the interplay of conditions that together cause an individual to have a prognosis of 6 months or less. At this point, the proposed definition is open for comments. However, my guess is that in the final determination there may well be a clear differentiation between the definition of ‘terminal illness’ and that of the ‘principle/hospice-qualifying diagnosis’ to better underscore the prognostic implication and comprehensive nature of the former.
Since our last Part D blog, CMS issued the Revised Guidance for Part D, on July 18th, 2014, effective as of that date. There are some detailed, comprehensive resources (listed below) that address this complex issue. The purpose of this blog is to synthesize and recap “what’s new” in the Revised Guidance for Part D and highlight tools for navigating these changes.
May I be the first to acknowledge that I am certainly not a poet! Let me also be clear that this is written with the utmost of respect for the sacred responsibility that we elect in accepting the privilege of caring for those at the end of their lives. However, in the stressful times in which we are living, with increasing regulatory and public scrutiny, burdensome processes (e.g., The Hospice Item Set, CR 8358, etc.), and unclear guidance (e.g., Medicare Part D), my hope is that a small dose of humor might help in palliating some of the symptoms of confusion, frustration and disempowerment. And so yes, this blog post is ‘related’!