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Hospice Billing Issues
Will hospices be able to bill for counselors and MFTs separately who are providing counseling in bereavement services? Hospice currently gets payment for bereavement services but not on a fee for service basis like nurses and others. Just curious if that will add additional payment for hospice services if a Counselor or MFT is on staff?
The short answer is no; hospices will likely not be able to bill for Part B services on top of their hospice per diem for services rendered by MFTs. Clinical Social Workers are not able to bill for Part B services on top of the per-diem rates, unless they are providing treatment for conditions unrelated to their terminal illness. They can receive SIA payments (defined below) for care rendered in the final 7 days of a hospice patient’s life.
Generally, when hospice coverage is elected, the beneficiary waives all rights to Medicare Part B payments for services that are related to the treatment and management of his/her terminal illness during any period his/her hospice benefit election is in force, except for professional services of an attending physician not employed by the hospice (which may include a nurse practitioner or physician assistant.) (Medicare Claims Processing Manual Chapter 11, Section 10.) Other than this narrow exception, Medicare payment for hospice care is made at one of four predetermined rates for each day that a Medicare beneficiary is under the care of the hospice. The four rates are prospective rates; there are no retroactive adjustments other than the application of the statutory “caps” on overall payments and on payments for inpatient care. The four rates are called: routine home care, continuous home care, inpatient respite care, and general inpatient care. (Medicare Benefit Policy Manual Chapter 9, Section 40.)
A hospice service intensity add-on payment (“SIA payment”) may apply when social workers or nurses provide care, during routine home care, in the last seven days of life. (Medicare Claims Processing Manual Chapter 11, Section 30.2.2.) The SIA payment is in addition to the routine home care rate. The SIA payment is provided for visits of 15 minutes up to 4 hours per day. Note, the time of a social worker’s phone calls is not eligible for an SIA payment. Commentators have noted this add-on payment is underutilized in the hospice industry, (https://hospicenews.com/2019/05/20/medicare-service-intensity-add-on-underused-by-hospices/).
