In recent blogs, we outlined medical Medicare review strategies; explained probe and educate (PE), as well as Targeted Probe and Educate (TPE), Medicare’s new medical review strategy; we offered strategies for preparing and submitting TPE documentation; and we outlined the TPE claims review process. In this blog, we will share some of the top hospice agency TPE denial reasons.
To better educate you on TPEs, it’s instructive to know about the top hospice TPE denial reasons. Below, we’ve outlined the top 5 from October-December 2017 as ranked by CGS Administrators, LLC (CGS), along with potential remedies for each. Following these, we also included the top hospice medical review denial as ranked by Palmetto GBA, which, along with CGS, is one of the nation’s largest Medicare Administrative Contractors (MACs).
(1) Denial code: 5PM01: Information provided does not support a terminal prognosis of six months or less.
Potential remedy/remedies
Documentation is essential in “painting the picture,” especially for patients that:
Documentation to support the terminal prognosis at the time of the hospice admission may include:
Documentation to support the terminal prognosis throughout the hospice election encompasses the following:
Things to remember:
For more information: www.cgsmedicare.com/hhh/education/materials/pdf/Hospice_5pter_factsheet.pdf
(2) Denial code: 5PC09: The hospice plan of care does not meet the requirements set forth in the code of federal regulations.
Potential remedy/remedies
The Plan of Care (POC):
(3) Denial code: 5PC08: Face-to-face encounter requirements not met.
Potential remedy/remedies
Additional Information:
(4) Denial code: 5PC01: The physician narrative statement was not present or was not valid.
Potential remedy/remedies
As of Oct. 1, 2009, the physician’s brief narrative explanation of the clinical findings that supports a life expectancy of six months or less is part of the certification and recertification forms, or is an addendum to the certification and recertification forms.
(5) Denial code: 5PX06: The notice of election is invalid because it doesn’t meet statutory/regulatory requirements.
Potential remedy/remedies
To be valid, the election statement must include the following information:
*Palmetto GBA top denial code: 56900: auto denial – requested records not submitted.
Medical records were not received in response to an ADR in the required time frame; therefore, we were unable to determine medical necessity. Failure to submit requested documentation will result in a denial 100% of the time.
Potential remedy/remedies
For more information: www.palmettogba.com/palmetto/providers.nsf/vMasterDID/ AVJKFF4883?OpenDocument
TPE notifications are posted in the DDE system at the fiscal intermediary. To ensure timely notification of TPE requests, your hospice agency should regularly check the DDE system because you only have 30 days to respond to a TPE. Your agency should also track the TPE requests and responses on a spreadsheet or grid that includes applicable deadlines for response. This not only helps your agency keep track of the status of TPE responses, but it will be useful if you choose to appeal any claims that are denied as part of a probe.
By submitting a cover letter highlighting the evidence that supports patient eligibility, your agency stands a better chance of avoiding claims denials and avoiding targeted medical review. The cover letter should be written concisely (approximately two pages in length) to make your agency’s case for patient eligibility during the claim period at issue. It should also point to documentation that supports your agency’s position.
The terminal condition of a hospice patient will occasionally plateau, or even briefly improve, during a month. This does not mean that the patient is not terminally ill. In this case, it is helpful to provide documentation from claim periods outside of those requested on the TPE to show the trajectory of the patient’s disease, along with a carefully crafted cover letter explaining the information is relevant to the TPE period.
Hospice agencies sometimes make the mistake of ceasing billing when they find themselves in the midst of a probe. However, this will simply prolong the probe because as discussed above, the intermediary will need to pull billed claims in order to complete its probe. The irregular billing patterns may also raise additional questions with the intermediary.
Related Blogs:
Medicare Medical Review Strategies
Understanding Targeted Probe and Educate for Hospice Agencies
Preparing and Submitting Your TPE Documentation
Navigating the Claims Review Process
Contact Richter Healthcare Consultants:
Do you have questions about TPE, or other clinical challenges? Read our Targeted Probe and Educate for Hospice Agencies e-book or call Richter’s clinical education consultants at 866-806-0799 to schedule a free consultation.
Donna Berry is the Revenue Cycle Manager for Home Health and Hospice with Richter Healthcare Consultants.
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