CMS Reminder on Election Statements

CMS is reminding hospice providers that it will continue to look at General Inpatient (GIP) and the NOE for hospice care.  The OIG has been reviewing data on GIP and NOEs and has come to some startling conclusions according to their report.

One-third of all NOEs did not include, as required, a beneficiary’s waiver of coverage which states that hospice care is palliative and not curative. 14% of all NOEs did not meet the requirements of the physician certification.  In these instances, the physician did not certify that the patient was terminally ill and documentation showed little interest or involvement in the determination that the patient was indeed qualified for hospice care.

Providers should review their NOEs and use MLN Matters SE1631 as a guide. SE1631 includes a sample NOE with all of the required components.  For providers that use an EMR/software, the NOE should be compliant. However, we have seen from numerous surveys that reliance on an EMR can result in severe deficiencies.  Don’t simply rely on your EMR – verify compliance in your program’s formats.  The EMRs are not a fool-proof method of operating, but rather a tool for compliance.