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CAPC Palliative Care Discussion Forum
Palliative Care Out-Patient Services
Non Profit Hospice seeking to create OPPC ProgramAuthor: LCforOPPC
Date: Mar 29, 2009 11:50 am
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1) determination of the services hospice can provide and bill requires review of federal and state legislation and regulation. Medicare will not reimburse a hospice provider for services that fail to meet the criterion of a 6-month prognosis if the disease pursues its expected course. In some States, Medicaid will pay for a longer projected prognosis - in those circumstances, eligibililty is determined by State statute - so in your case, you will need to reference the relevant provisions in South Carolina law.
2) Practitioner palliative care services are reimbursed under Medicare Part B provisions while hospice is reimbursed under Medicare Part A. If staff are to bill for palliative care per se, they must have the appropriate professional credentials (dictated by both Federal and State requirements) and each must have a registered Part B provider number. In some states, a hospice can bill Part B directly for palliative care services; in others, State Corporate Practice of Medicine Law precludes this option. We recommend that you get advice from a health care attorney in your State. In the case of non-Medicare/Medicaid billing, the insurance provider may also establish payment rules and rates.
3)You ask whether a hospice should consider a demonstration project with an affiliated hospital to provide out-patient palliative care services. Creating a continuum of palliative care including in-patient and out-patient services is desirable. Palliative Care of the Bluegrass is a good example of that partnership option. However, if the outcome you seek to achieve via the demonstration project is modification of legislative and/or regulatoroy constraint, you will want to involve key State decision makers in pre-authorization of the project. You will find that your State Hospice Association can be helpful in project framing and decision-maker outreach.
4) You inquire about the point of least resistance related to State-defined criteria for providing OPPC services. One avenue you have already identified is the demonstration project approach. It may also be helpful to work with the National Hospice and Palliative Care Organization to identify States with more flexible program definitions than currently exist in South Carolina - so that you can gather some data on experience and outcomes elsewhere. For example, hospices in other States have developed PACE programs and/or flexilbe long term care initiatives which provide access to palliative care services and funding sources.