Hospice SIA Billing Follows Existing Visit Reporting Rules
February 5, 2016 12:48 PM
In recent weeks National Association for Home Care & Hospice (NAHC) members have requested clarification related to new Centers for Medicare & Medicaid Services (CMS) Medicare Claims Processing Manual language (see section 30.2.2) indicating, “The SIA [Service Intensity Add-on] payment is provided for visits of a minimum of 15 minutes [emphasis added]and a maximum of 4 hours per day…” The desire for clarification was prompted by concern that under already existing hospice visit reporting rules visits of less than 15 minutes are reported as a single visit since visits of any length are rounded to the nearest 15-minute increment (“When recording any visit… providers should sum the time for each visit … rounding to the nearest 15 minute increment”),while the manual language on the SIA references visits of a minimum of 15 minutes. The general visit reporting guidance contained in The Medicare Claims Processing Manual contains no reference to a minimum number of minutes that qualify for reporting as a single visit unit for hospice services.
In response, NAHC sought guidance from CMS to ensure that -- despite the SIA manual language -- hospice providers are expected to report visits that ultimately qualify for the SIA in the same manner that they report all other visits. CMS has confirmed that reference to a “minimum of 15 minutes” was intended to describe the lower limit of the range of units (1 to 16) eligible for the SIA, and that visit reporting requirements have not changed. CMS also referenced Medicare Claims Processing instructions for home health agencies directing that “visits of any length are to be reported, rounding the time to the nearest 15-minute increment” as applicable relative to reporting of SIA visits.
NAHC cautions all hospice providers that any visits reported on claims must meet the definition of “visit” as specified in section 30.3 of the Medicare Claims Processing Manual: “To constitute a visit, the discipline…must have provided care to the beneficiary. Services provided by a social worker to the beneficiary’s family also constitute a visit. For example, phone calls, documentation in the medical/clinical record, interdisciplinary group meetings, obtaining physician orders, rounds in a facility or any other activity that is not related to the provision of items or services to a beneficiary, do not count towards a visit to be placed on the claim. In addition, the visit must be reasonable and necessary for the palliation and management of the terminal illness and related conditions as described in the patient’s plan of care.” NAHC also reminds hospices that post-mortem time should be recorded in 15-minute increments with the “PM” modifier and is NOT eligible for the SIA.