Archive for the ‘Psychiatric’ Category

Hospice Face-to-Face Encounter Requirement

Thursday, August 25th, 2011

This hospice encounter, like the home health face-to-face encounter, is causing concern among the industry. Agencies view it as yet another burden. Below we break down the regulation and look at “Who” may perform the face-to-face encounter, “What” all is required, and “When” must it take place.

“Who” may certify the face-to-face encounter?

Effective January 1, 2011, in response to the Patient Protection and Affordability Act, CMS added a “face-to-face encounter” requirement to the hospice certification requirements. The rule requires that hospice patients have a face-to-face encounter with a hospice physician or hospice nurse practitioner. The rule requires the same physician who has the encounter to certify the patient’s terminal illness.

Some flexibility has been added in the new final wage index published July 29, taking effect October 1, 2011. The face-to- face encounter will indeed become more flexible and will “allow any hospice physician to perform the face-to-face encounter regardless of whether that same physician recertifies the physician’s terminal illness and composes the recertification narrative.” (www.ofr.gov/OFRUpload/OFRData/2011-19488_PI.pdf).

A hospice physician is one who is employed by the hospice or contracts to perform work for the hospice. The hospice nurse practitioner must be employed by the hospice.

In the final rule of July 29, 2011, effective October 1, 2011, CMS rejected the request by the National Hospice and Palliative Care Organizations (NHPCO) to include physician assistants and clinical nurse specialists to perform the Face-to-Face encounter. The approved list continues to only include hospice physicians and nurse practitioners.

CMS did clarify that “hospice employee” does include employees of an organization which owns a hospice. There had been much confusion regarding whether health systems that employed nurse practitioners and owned a hospice  could have those practitioners perform the face-to-face encounters.

“What” additionally may be necessary?

Once the physician or nurse practitioner conducts the face-to-face encounter, they attest to the date of the encounter, and sign the attestation clause.

Since 2009, the physician must also document a narrative of clinical findings supporting life expectancy of six months or less.

With the new face-to-face encounter requirement, physicians must now include a narrative for the third beneficiary period and each subsequent benefit period. The narrative must delineate clinical findings with the face-to-face encounter that supports the life expectancy of six months or less.

The physician signature is required immediately below the narrative if it is a part of the certification form. If the narrative is a part of the addendum to the certification form, the addendum must also be signed by the physician.

“When” must the face-to-face encounter take place?

The face-to-face encounter must take place no more than 30 days prior to the patient’s third benefit period AND every subsequent benefit period thereafter. In the Open Door Forum on March 2, 2011, CMS was very clear that they expect a face-to-face encounter to be completed prior to the start of the third benefit period. However, CMS recently issued CR7337 to include exceptional circumstances for this requirement. In cases where a hospice newly admits a patient who is in the third or later benefit period exceptional circumstances may prevent a face-to-face encounter from being conducted prior to the start of thebenefit period. In this circumstance, a face-to-face which occurs within 2 days after admission will be considered timely. If the patient would die within 2 days of admission without a face-to-face encounter, the encounter requirement would be considered complete.

In the March 2, 2011 Open Door Forum, CMS was most direct in stating that the exception is meant for the last minute admission, weekend admissions, and other exceptional circumstances.

The new Rule effective October 1, 2011

CMS is seeking public reporting of quality data from hospice agencies. Public Reporting will begin with two indicators: 1) the percentage of patients whose pain was brought to a comfortable threshold within 48 hours of hospice admission and 2) a structural measure indicating the hospice has a quality assessment and performance improvement (QAPI) program.

Data collection will become mandatory CY2012 with data submission required by January 2013 for the structural measure and April 2013 for the quality measure. Hospices that do not submit quality data should expect the market-based update for 2014 reduced by two percentage points.

Data reporting is expected to increase with additional quality indicators. Most hospice leaders will not find this surprising.

Note that after the release of the CY2011 and the face-to-face encounter, CMS stated, “we will issue instructions to the contractors who perform medical reviews to ensure compliance with this regulation.” The Z-PICs, PSCs, and RACs are expected to be more active within the Hospice industry. Compliance plans not yet mandated have become expected and essential. Tracking the signed face-to-face encounter is a requirement for payment; another essential element for the billing review.

Psychiatric Nursing in Home Health

Wednesday, May 25th, 2011

During these past few weeks, we have seen an increase in questions regarding psychiatric nursing services. More agencies are considering new programs. One agency has shared that Palmetto is no longer asking to see resumes of psychiatric nurses, but agencies must verify with EVERY MAC before beginning a psych program.


The CMS Publication 100-2, Chapter 7, §40.1.2.14, simply says, “Psychiatrically trained nurses are nurses who have special training and/or experience beyond the standard curriculum required for a registered nurse.”  MACs can establish the special training and experience required.  A home health agency should contact its MAC and look at the MAC website for any special qualifications needed.

Introduction

CMS has recognized psychiatric home care as a reimbursable service since 1979, but nationwide, proportionately fewer home health agencies actually provide this service. The exact number of agencies that include psychiatric home care is unknown. There has been a reluctance of agencies to implement psych programs and there are many reasons for these decisions.

First of all, the skills of a psychiatric nurse are required and this specialist is usually more difficult to find. Second, the psychiatric patient is frequently more disorganized and needy than other patients causing the case management responsibilities to become time consuming and complex. Third, this patient is frequently homebound questionable.

CMS Publication 100-2, Chapter 7, §430.1.1, states that a patient with a psychiatric problem may be considered homebound if “the illness … is of such a nature that it would not be considered safe to leave home unattended, even if he or she does not have any physical limitations.”  The homebound status of patients with psychiatric needs require well written, clearly stated clinical visit notes, because there may not be physical impairments, and homebound status must be clearly delineated. Any patient in a certified home health program may leave their home for specific reasons, as identified in Chapter 7 of the Medicare Provider Benefits Manual. Homebound status for a patient suffering from a mental health issue may be just as painful and debilitating, but may not manifest itself with physical symptoms or behaviors.

Homebound status (for a patient suffering from a mental illness) may need to be evaluated as a clinician would evaluate a patient suffering from dementia or Alzheimer’s diseases That patient may have few or no physical limitations and yet would be deemed unsafe to leave his/her home unattended. The patient, in this example, could be considered homebound.

However, if the patient with a psychiatric condition leaves home regularly for reasons other than to visit the physician, he/she may not be considered homebound; the same as any other home health patient in the certified agency.  An example may be that of patient with a mental health issue attending partial hospitalization.

Partial Hospitalization

In 1999, CMS, then known as HCFA, stated that a patient in a partial psychiatric hospitalization program does not qualify for psychiatric home care services.  The partial hospitalization program should be able to provide necessary psychiatric services. The homecare services must be psych-related. If they are not focused on a psychiatric issue, the home health agency must evaluate the patient’s needs, just as it would normally do with any other patient, and evaluate whether home care services are in keeping with medical necessity and homebound status.

What is Psychiatric Home Health Nursing?

What is unique about psychiatric home care? Although psychiatric home care is bound by the same CMS regulations that define other types of home care, these regulations are largely non-specific for the psychiatric patient. This means the clinician must be specific as to symptoms and document those plans and interventions, as well as work closely with the physician.

On the surface, psychiatric care appears to be very eclectic, but there is much depth of choice for intervention strategy. Although psychiatric nurses may draw upon crisis intervention techniques as noted by Duffy, Miller, and Parlocha (1993) and Beck’s or Montgomery-Asburg Depression Inventories, Young Mania Scale, Sheehan Anxiety Scale along with Cognitive Restructuring therapy, there are a number of other psychiatric intervention models that can be very useful: psycho-education, interpersonal reflective, supportive, individual, and/or brief therapy, as well as behavior therapy, relaxation, contract, and reward provisions.

The psychiatric nursing home care plan must be intermittent. This short term program frequently focuses on improved problem-solving, stronger ego boundaries, and enhanced self-concept. This is important with patients of all ages, but the need is seen often with elder patients who are suffering significant losses in life.

With patients suffering from depression, the psych nurse frequently seeks ways to displace internalized anger outwardly. Activities designed by an occupational therapist can augment the skills of the psych nurse. An increasing number of home health agency psych programs are adding this discipline because of the physical activities that can be beneficial.

Stress management and education of stress strategies are commonly taught. Many patients have weak or fragile coping mechanisms that require reinforcement or a new approach.

Forming linkages between the patient and needed community services is a vital component of the role of the psychiatric home care nurse. This type of nursing brings an existential/spiritual concern and dimension to patient care. The clinician frequently provides support to a patient with low self esteem and a belief that the community has prejudged them. The clinician can assist the patient to cope with behaviors and approaches patients with an attitude of respect, reinforcing or assisting to rebuild worth and dignity.

Demoralized individuals are frequently seen in this program. Patients may lack energy, frequently because of losses; losses of friends, of family, of job, of status, of money, of respect, and others. This patient frequently requires a nurse whose plan with the patient requires assessment of the patient, their role within the family, the family support system, teaching use of psychotherapeutic techniques to facilitate change, medication management, and supervising their care in a supportive fashion that sustains physical, emotional, and spiritual life,

Relationship Building and Trust

The clinician will build relationships established on trust, caring, compassion, empathy, education, and hopefulness. The RN will use verbal and non-verbal communication techniques to convey interest in the patient, to assess what the patient wants to accomplish, to assist with care planning and goal achievement, and to clarify the boundaries of the relationship, and lastly to affirm the patient has value and worth.

Medication Management

Medication management is frequently a need for patients and is one of the main reasons for hospitalization. CMS identifies a significant portion of hospitalizations are due to poor medication management. Some patients do not understand the reasons they has been prescribed certain medication. Sometimes, patients do not like the side effects and feel those effects are nearly as bad as the psychiatric condition. Some patients cannot afford their meds and still others do not wish to take their meds as they provide a constant reminder of a condition many wish could be forgotten. One patient once shared, “I look in the mirror, put the pill in my mouth, bring the glass to my lips, and know I am ill.” Unless this issue is addressed, the chance that this patient will become medication non compliant is great.

Medication management intervention must be individual. Certain patients may require a contract by which they contractually agree to take their medications as prescribed. It is this tangible “document” that assists with compliance reinforcement. Teaching about major effects of the medications can be an empowering experience. For those patients whose cognitive impairment is apparent, modified pictorial teaching tools may be necessary. Role-playing, coaching, and teaching can be a part of  an empowering strategy.

Summary

Patients with stressors, depression, and cognitive impairments can frequently benefit by a psychiatric nurse. The program must be comprehensive aiding the patient through stabilization, caring, and reinforcement of strengths. A therapeutic relationship built upon trust can provide acceptance to teaching and compliance with medication. Leaving the patient more calm, organized, stronger, and knowledgeable can assist the individual to improve links with family, friends, and the community and be more compliant with their medication regime.

The psychiatric program can be a strong support to total quality care and improved outcomes.