Certification of Terminal Illness

Hospice agencies often make these 5 mistakes in the written physician's narrative for hospice certification

A few physicians consistently top the New York Times bestselling authors list, but many doctors look at writing as a chore – particularly when it comes to crafting the important physician’s narrative required by the Centers for Medicare and Medicaid Services (CMS) for all hospice patients.

“Physicians tend to take all kinds of shortcuts with the narrative but Medicare doesn’t like those shortcuts,” says Heather Calhoun, who serves as Director of Special Projects and Appeals for Home Health Solutions. “There’s really no way around it. The narrative is an integral part of the Certification of Terminal Illness (CTI).”

The physician’s narrative is one of three essential parts of the written CTI set out under federal regulations at §418.22. Regulations also require an attestation by the physician that the hospice patient has less than six months to live if the terminal illness runs its normal course, and clinical documentation supporting that finding.

Of those three requirements, the physician’s narrative generates the most confusion for hospice agencies and their medial directors, according to Heather.

“Many hospice agencies use a form for the CTI, and they’ll try to add boxes that the physician can just check off, or other ways to make it easier than actually writing out the narrative in paragraph form,” she said. "But that won't work."

5 common problems to avoid

Here are five other shortcuts Medicare doesn’t like:

· Diagnoses lists instead of sentences “There’s really no checklist that is going to work as a narrative,” Heather said. “CMS is looking for some specific information about the patient in paragraph form.”

· A generic format for all “There is no such thing as a one-size-fits-all narrative,” Heather said. “The narrative must be patient-specific, describing what is going on with that particular patient and why hospice care is appropriate at this time.”

· Copying and pasting Avoid copying and pasting any other parts of the record, Heather said. The narrative needs to be a new and original creation based on the patient's medical record.

· Having someone else write the narrative “The narrative should include an attestation by the physician that he or she has composed after reviewing the record and examining the patient,” Heather said. “This means the physician has to write it.”

· Leaving off the terminal illness “This actually happens more than you’d think,” Heather said. “Generally, it gets left off because the physician is focusing so hard on crafting the narrative that they just forget to include the terminal diagnosis.”

7 steps to make it easier

Any or all of those common mistakes will get the CTI booted by a Medicare administrative contractor, Heather said.

But writing the physician’s narrative doesn’t have to be difficult. Home Health Solutions has

put together a simple 10-page guide to the Certification of Terminal Illness which breaks down the narrative into 7 simple steps!

The CTI Guide is available in The Solutions Shop for just $21.99 – now with a complimentary link to Heather’s October webinar on the OIG report on hospice. While you're browsing the online store, be sure to check out our QAPI-compliant Performance Improvement Project on Improving Bereavement Plan Compliance. It's a great deal -- available for just $9.99!