Prepare For Actual On-Site Auditor Questions and Requests

a. Describe how the hospice bills the Medicare or Medicaid program.

• Identify the employees responsible for billing (current and during the audit period).
• How often is Medicare/Medicaid billed?
• What controls are in place to ensure the correct CPT/Revenue code is being billed?
• How is billing for Medicare/Medicaid (dual) eligible beneficiaries handled? Are there specific billing policies?

a. What criteria are used to determine beneficiary eligibility for hospice benefits?

• Does the hospice make use of any generally accepted industry guidelines (such as LCDs) when determining patient eligibility? Name guidelines, such as LCDs, if they are used.
• Do hospice staff utilize tools such as Palliative Performance Scale (PPS), functional Assessment Staging Test (FAST), New York Heart Association (NYHA) classification, etc.?

b. Who determines if a beneficiary is appropriate for hospice?

c. Who determines if a beneficiary is appropriate for general inpatient or continuous care, how is that determined, and what criteria are applied?

a. Does the hospice elicit physician participation in the Interdisciplinary Team (IDT) meetings and Plan of Care coordination?

• Who is required to attend these meetings?

b. Are IDT minutes part of the patient record?

• If not, where are they housed; can they be provided?

a. How are patient assessments performed? Is there a standardized method?

• Who performs and documents these assessments?
• Is there a supervisory review of these assessments?
• How often are they performed?

b. Does the hospice make use of Minimum Data Set (MDS) data for recipients who are residents of a nursing facility?

• Who has access to this information?
• Is this documentation routinely maintained in the recipients’ records?

c. What is the frequency of patient encounters with the Medical Director and/or the Attending Physician or Certified Registered Nurse Practitioner (CRNP)/Physician’s Assistant (PA)?

• How often do Face to Face Visits occur? d. What documents are prepared to record the rendering of service, and how frequently is this documentation created e.g., right after service is rendered, weekly, etc.?

e. How and where are the provider’s medical records stored?

• Electronic Health Records?
• Company which provides Electronic Health Records

f. What is the frequency for checking weights and/or other vitals? Who acquires and documents vitals?

g. What is the method and frequency of Mid-Arm Circumference (MAC) measurements?

h. What is the frequency of oximetry measurements?

i. Are blood pressure (B/P) measurements records by the arm or wrist cuff?

• Repeated if out of a specified range?

j. Can hospice staff make changes to medical documentation? Who and how?

a. Are there written policies and procedures related to clinical assessments and measurements?

b. Are there written policies and procedures related to service documentation?

c. Does hospice staff have access to the hospice’s policies and procedures? Where are they kept?

a. Where do you provide hospice services? What percentage receives services in their residence, nursing home, assisted living facility, hospital, etc.?

b. Does the hospice have contractual arrangements with other providers, or is it owned by a company that also has ownership of other facilities in the area? Is so, describe the arrangement (i.e., nursing homes, rest homes, assisted living, hospitals).

• Who is the designated liaison between the hospice and the other service providers?
• How is the payment to the nursing facility handled?

c. How many hospice patients do you typically service in a given month (or year)?

d. Does the organization provide other health related services beside hospice services such as nursing home care? If so, describe.