August 24, 2016

Billing for Services After Death

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In 2006, David Brennan, then-president of international pharmaceutical giant AstraZeneca, famously stated that "Americans have a funny approach to this (the option of forgoing chemotherapy at the end of life). We think death is optional."

While death is not optional, the administrative aspects of dying can be more complicated than many of us realize.

In my practice, I once cared for a rather ill hospitalized patient. The patient improved and was discharged with home health services. The home care agency developed a plan of care and started executing it. But a week later, the patient died. 

A few days later, I received a copy of the plan of care for that patient for review and signature. This service is reimbursed with HCPCS code G0180. But when I submitted the claim, indicating the date of service as the date that I reviewed and signed the document, it was denied, along with a notation that the patient was deceased on that date of service. It is true, but billing rules required that I billed with the date I actually reviewed and signed the form, not the date on which the care plan was developed.

A recent post on an online user group outlined a similar dilemma faced by a hospital. They reported that they were experiencing difficulty with their Medicare Administrative Contractor (MAC), which had processed a claim associated with a patient who expired at their facility, but the funeral home listed an incorrect date of death on the death certificate.

The claim was denied because the hospital had “incorrect” information. The funeral home corrected the death certificate, the MAC updated its system, and the Social Security office updated its system as well. But the claim is still not being approved for payment because the Medicare common working file (CWF) had not been updated. 

According to the MAC and the Social Security office, this can only be done via a family member contacting them and requesting the correction. The hospital has left several messages with family members (who have no vested interest in ensuring that the CWF is correct), with no response. And until the CWF gets corrected, the claim cannot be paid.

The same week that this post appeared, the New England Journal of Medicine published an article by the chief medical officer of Press Ganey that related the story of a patient of his whose spouse had died. Several months later, the patient’s credit cards were suddenly rendered invalid, his bank account was frozen, and his Medicare and supplemental coverage was cancelled. It turned out that there was a simple data entry error in the Social Security death master file created at the time the wife’s death information was entered, rendering the husband “dead” along with his wife. Data from this file is transmitted to healthcare and finance organizations to ensure that the Social Security information of dead people is not used to bill for medical services or to conduct financial transactions. With great difficulty, he was able to “resurrect” himself in the eyes of the various agencies.

So whether it is billing for appropriate services after the date of death, trying to correct an incorrect date of death, or trying to prove that claims of one’s death were premature, it is clear that while death is not optional, it certainly is complicated.

 About the Author

Ronald Hirsch, MD, FACP, CHCQM is vice president of the Regulations and Education Group at Accretive Physician Advisory Services at Accretive Health. Dr. Hirsch’s career in medicine has included many clinical leadership roles at healthcare organizations ranging from acute-care hospitals and home health agencies to long-term care facilities and group medical practices. In addition to serving as a medical director of case management and a medical necessity reviewer throughout his career, Dr. Hirsch has delivered numerous peer lectures on case management best practices and is a published author on the topic. He is a member of the Advisory Board of the American College of Physician Advisors, a member of the American Case Management Association, and a fellow of the American College of Physicians.

Contact the Author

RHirsch@accretivehealth.com

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Ronald Hirsch, MD, FACP, CHCQM

Ronald Hirsch, MD, FACP, CHCQM is vice president of the Regulations and Education Group at R1 Physician Advisory Services. Dr. Hirsch’s career in medicine includes many clinical leadership roles at healthcare organizations ranging from acute-care hospitals and home health agencies to long-term care facilities and group medical practices. In addition to serving as a medical director of case management and medical necessity reviewer throughout his career, Dr. Hirsch has delivered numerous peer lectures on case management best practices and is a published author on the topic. He is a member of the Advisory Board of the American College of Physician Advisors, a member of the American Case Management Association, and a Fellow of the American College of Physicians. Dr. Hirsch is a member of the RACmonitor editorial board and is regular panelist on Monitor Mondays.

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