The requirements for the hospice notice of election (the document that the patient signs) is discussed in the Medicare Benefit Policy Manual Chapter 9, 20.2.1.1. The language is brief only stating that the "signature of the individual or representative" is required.
From a regulatory perspective, how does CMS treat a situation where an emergency admission is needed, the patient is unable to sign due to cognitive factors and the patient representative is not physically present to sign the NOE but has provided telephone consent. Does CMS:
- expect the hospice to delay admission until the representative is able sign and return the NOE back to the hospice?
- admit the patient without the representatives signature but delay billing CMS until the signature by the patient representative is returned?
- allow an alternative method for patient signature, such as a dual witness of a telephone consent?
The only signature requirement language I could find was in the Medicare Program Integrity Manual Chapter 3, section 3.3.2.4 and was more directive towards physician/employee signatures and not so much patient/rep signature requirements.
Any help on what the regulations require or how your hospice handles these situations would be much appreciated, thank you!
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Matthew Cranny
Avera McKennan Home Care & Hospice
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