Confidentiality, Privacy and Security

I use to work in post acute setting.  I would recommend referencing COPs 418.22.  There is a specific subsection for sources if certification. See excerpt below:

(c) Sources of certification.
(1) For the initial 90-day period, the hospice must obtain written certification
statements (and oral certification statements if required under paragraph
(a)(3) of this section) from--
(i) The medical director of the hospice or the physician member of the
hospice interdisciplinary group; and
(ii) The individual's attending physician if the individual has anattending
physician. The attending physician must meet the definition of
physician specified in § 410.20 of this subchapter.
(2) For subsequent periods, the only requirement is certification by one of the
physicians listed in paragraph (c)(1)(i) of this section

------------------------------
Diane Lerch
Division Director of Coding and CDI
Tampa General Hospital
------------------------------

Original Message:
Sent: 08-14-2020 13:50
From: Barbara Naimark
Subject: Hospice - Verbal and Written Initial certification

Looking for expertise in hospice - Does the physician who gives the verbal cert for admission have to be the same physician who writes the certification?  I can not find specific regs that speak to the same physician or not.

Original Message:
Sent: 8/15/2020 6:57:00 AM
From: Diane M Lerch, RHIA,CHPS,CCS,CHTS-TR,CHTS-PW,CHC, CCDS
Subject: RE: Hospice - Verbal and Written Initial certification

I use to work in post acute setting.  I would recommend referencing COPs 418.22.  There is a specific subsection for sources if certification. See excerpt below:

(c) Sources of certification.
(1) For the initial 90-day period, the hospice must obtain written certification
statements (and oral certification statements if required under paragraph
(a)(3) of this section) from--
(i) The medical director of the hospice or the physician member of the
hospice interdisciplinary group; and
(ii) The individual's attending physician if the individual has anattending
physician. The attending physician must meet the definition of
physician specified in § 410.20 of this subchapter.
(2) For subsequent periods, the only requirement is certification by one of the
physicians listed in paragraph (c)(1)(i) of this section

------------------------------
Diane Lerch
Division Director of Coding and CDI
Tampa General Hospital
------------------------------

Original Message:
Sent: 08-14-2020 13:50
From: Barbara Naimark
Subject: Hospice - Verbal and Written Initial certification

Looking for expertise in hospice - Does the physician who gives the verbal cert for admission have to be the same physician who writes the certification?  I can not find specific regs that speak to the same physician or not.

Good morning Barbara! Kelly McLendon let me know you had asked this, so I phoned a friend who works for a Hospice in Florida.

She indicated her company has in place that physicians often cover for one another so they allow one to give the verbal and another to give the written certifications.

She did also point me to the CMS Manual, which I've attached the section she suggested.

I hope this helps!

------------------------------
Kelly Cooper, RHIA, CCS
Regional HIM
KCooper.HIM@gmail.com
Florida - SNF/LTC/LTPAC
------------------------------

Original Message:
Sent: 08-15-2020 09:16
From: Barbara Naimark
Subject: Hospice - Verbal and Written Initial certification

Thanks Diane

Original Message:
Sent: 8/15/2020 6:57:00 AM
From: Diane M Lerch, RHIA,CHPS,CCS,CHTS-TR,CHTS-PW,CHC, CCDS
Subject: RE: Hospice - Verbal and Written Initial certification

I use to work in post acute setting.  I would recommend referencing COPs 418.22.  There is a specific subsection for sources if certification. See excerpt below:

(c) Sources of certification.
(1) For the initial 90-day period, the hospice must obtain written certification
statements (and oral certification statements if required under paragraph
(a)(3) of this section) from--
(i) The medical director of the hospice or the physician member of the
hospice interdisciplinary group; and
(ii) The individual's attending physician if the individual has anattending
physician. The attending physician must meet the definition of
physician specified in @ 410.20 of this subchapter.
(2) For subsequent periods, the only requirement is certification by one of the
physicians listed in paragraph (c)(1)(i) of this section

------------------------------
Diane Lerch
Division Director of Coding and CDI
Tampa General Hospital

Original Message:
Sent: 08-14-2020 13:50
From: Barbara Naimark
Subject: Hospice - Verbal and Written Initial certification

Looking for expertise in hospice - Does the physician who gives the verbal cert for admission have to be the same physician who writes the certification?  I can not find specific regs that speak to the same physician or not.

Thanks Kelly-
I've read Chapter 9 backwards and forwards - to find the exact wording on this - but what  your friend said is of great value.

------------------------------
Barbara Naimark
Compliance Manager
------------------------------

Original Message:
Sent: 08-17-2020 10:27
From: Kelly Cooper
Subject: Hospice - Verbal and Written Initial certification

Good morning Barbara! Kelly McLendon let me know you had asked this, so I phoned a friend who works for a Hospice in Florida.

She indicated her company has in place that physicians often cover for one another so they allow one to give the verbal and another to give the written certifications.

She did also point me to the CMS Manual, which I've attached the section she suggested.

I hope this helps!

------------------------------
Kelly Cooper, RHIA, CCS
Regional HIM
KCooper.HIM@gmail.com
Florida - SNF/LTC/LTPAC

Original Message:
Sent: 08-15-2020 09:16
From: Barbara Naimark
Subject: Hospice - Verbal and Written Initial certification

Thanks Diane

Original Message:
Sent: 8/15/2020 6:57:00 AM
From: Diane M Lerch, RHIA,CHPS,CCS,CHTS-TR,CHTS-PW,CHC, CCDS
Subject: RE: Hospice - Verbal and Written Initial certification

I use to work in post acute setting.  I would recommend referencing COPs 418.22.  There is a specific subsection for sources if certification. See excerpt below:

(c) Sources of certification.
(1) For the initial 90-day period, the hospice must obtain written certification
statements (and oral certification statements if required under paragraph
(a)(3) of this section) from--
(i) The medical director of the hospice or the physician member of the
hospice interdisciplinary group; and
(ii) The individual's attending physician if the individual has anattending
physician. The attending physician must meet the definition of
physician specified in @ 410.20 of this subchapter.
(2) For subsequent periods, the only requirement is certification by one of the
physicians listed in paragraph (c)(1)(i) of this section

------------------------------
Diane Lerch
Division Director of Coding and CDI
Tampa General Hospital

Original Message:
Sent: 08-14-2020 13:50
From: Barbara Naimark
Subject: Hospice - Verbal and Written Initial certification

Looking for expertise in hospice - Does the physician who gives the verbal cert for admission have to be the same physician who writes the certification?  I can not find specific regs that speak to the same physician or not.

Barbara,
I am in hospice/home health as well, but for some reasons I missed your question. You already have your answers, but I just wanted to add that both the medical director and the attending physician have to sign. It is best to not have one of your facility's physicians just give the verbal, another write the certification with the narrative statement in addition to the attending's signature.
It is doable; however, when it is time to fulfill ADR, it can be troublesome. I have been through that! Medicare contractors may want you to provide the written certification of the physician (medical director) who gave the verbal order at your facility level. That is why in our organization we have implemented that the verbal order must come from the physician who writes the statement.
In regards to external attending physicians, different physicians can do that. One can give the verbal and one signs as the attending.

------------------------------
Louise Boucicaut MS, RHIA
Corporate Medical Records Manager
Community Hospice and Palliative Care
------------------------------

Original Message:
Sent: 08-14-2020 13:50
From: Barbara Naimark
Subject: Hospice - Verbal and Written Initial certification

Looking for expertise in hospice - Does the physician who gives the verbal cert for admission have to be the same physician who writes the certification?  I can not find specific regs that speak to the same physician or not.