Posts tagged Business Practice
As hospices and palliative care services evolve into advanced palliative care organizations with greater scope and influence over late-life care within their communities, a “new” physician executive role is emerging along the career path for HPM physicians. This role is broader than the traditional senior medical director or chief medical officer positions, and is progressing toward what we refer to as the “chief community palliative care officer”.
These physician executive positions have proven to be instrumental in shaping late-life care practices by applying management competencies to:
-build and sustain relationships that evolve into community-wide palliative care networks
-disseminate throughout a community the use of metrics and evidence-based practices to hold practitioners to high standards of performance
-inspire referring physicians and HPM medical staff members to meet clinical outcomes and family satisfaction metrics
-envision and stimulate a change process that coalesces the community around new models of late-life care
Daunting challenges, to be sure. As hospice executives and HPM physicians come to grips with impending rules around face-to-face recertification requirements, and other day-to-day operational issues, we would all do well to remain mindful of the strategic leadership objectives that will ultimately determine how successful we are in transforming late-life care in the US. We’ve seen the importance of the role of HPM leadership in exemplar communities across America. To “spread the science ” of HPM is our next challenge.
The first piece of education reviews the basic Center for Medicare & Medicaid Services (CMS) requirements for authentication of services provided or ordered. When CMS reviewed numerous examples of CERT signature denials, they found in almost every instance that the documentation was acceptable. Services were denied because of one of four “not acceptable” signature reasons, including
1. Illegible, unrecognizable handwritten signature or initials
2. Unsigned “typewritten” progress notes with a typed name only
3. Unverified or unauthorized electronic signatures
4. No indication of the rendering physician/practitioner
The Palmetto GBA Medical Directors strongly encourage the following improvements
1. Be sure a handwritten signature is a mark or sign by an individual on a document to signify knowledge, approval, acceptance or obligation
2. Records should clearly indicate they have been “electronically signed by” and include a date/time, including verbiage that makes this clear
3. Establish a protocol to ensure valid signatures are affixed to every order, record, or report within a reasonable time frame (i.e., customarily 48-72 hour after the encounter – but certainly before the claim is submitted to CMS for payment)
Additional information about the CERT program is available on the Palmetto GBA website under the CERT link. This focus is likely to apply to other intermediaries soon, so watch for additional educational updates and start looking into your current processes.