Key CTI Audit Compliance Components

Welcome to this edition of Hospice Excellence where we dive into critical topics to help hospice providers stay compliant, informed, and prepared. Today, we’re focusing on the Certification of Terminal Illness (CTI) and what to watch for when doing an internal audit or what to expect with an external audit. For hospice agencies, the CTI is one of the most scrutinized documents in these reviews. Let’s look at some of the essential components that auditors look for—and how to ensure your documentation meets the mark.

What Are External Auditors Looking For in a Hospice CTI?

When reviewing a CTI during a TPE or ADR audit, CMS focuses on several critical compliance components. Here are the top areas you need to get right:

1. Physician Signature

• The certifying physician’s signature must be present, legible, and dated.
• Nurse practitioners and physician assistants cannot certify or re-certify hospice patients.

• Common Errors: As basic as it seems, missing, illegible, or incomplete physician signatures are one of the most common reasons for denials.

2. Timeliness

• The CTI must be completed within the required timeframe:
• Initial certification: Initial certifications may be completed up to 15 days before the election. If the written certification cannot be obtained within two calendar days of the start of care, the verbal certification must be within that timeframe, with the written certification finalized no later than two calendar days after care begins.
• Recertification: Recertifications may be completed up to 15 days before the next benefit period begins.
• Make sure the written certification/recertification is signed and dated before billing Medicare, or their claim(s) may be denied. Late certifications can result in payment denials.
• Common Error: Not having both the hospice medical director and attending physician (if applicable) sign the initial certification as required.

3. Medical Necessity Documentation

• The CTI must document evidence supporting the patient’s terminal prognosis (life expectancy of six months or less if the illness runs its normal course).
• This includes clinical findings and supporting data.
• Common Error: Diagnosis and findings do not support medical necessity for hospice and reflect a custodial level of care.

4. Narrative Statement

• A narrative written by the certifying physician with an attestation statement is required.
• This statement should explain why the patient’s condition meets hospice eligibility criteria. Generic or vague narratives are often flagged during audits.
• Use both qualitative and quantitative information to support the decline from one benefit period to the next.
• Common Error: The physician's narrative does not include a statement attesting that it was composed by the physician.

5. Face-to-Face Encounter Documentation

• For new admissions going into in the third or after, with VERY FEW exceptions, a face-to-face encounter must be conducted by a hospice physician or nurse practitioner prior to the start of the new benefit period.
• Documentation must include observations supporting continued eligibility.
• The encounter must occur no more than 30 calendar days before the third benefit period recertification and each subsequent recertification.
• Common Error: Face-to-face was scheduled but not completed timely.

Why Does This Matter?

Audits like TPE's are said to be designed to highlight potential errors, educate providers, and reduce improper payments, but they can also lead to significant financial consequences if issues are identified. Denials related to CTIs are preventable with proper training, internal audit processes, and attention to detail.

How Can You Prepare?

1. Conduct Regular Internal Audits: Review your CTIs to ensure they meet all compliance requirements, especially before submitting claims.
2. Educate Your Team Train physicians, nurses, and administrative staff on what CMS expects in a compliant CTI.
3. Respond Promptly: If selected for an audit, respond quickly and thoroughly to requests for documentation.
4. Leverage Technology: Most electronic medical record (EMR) systems have systems in place that can help reduce errors

Stay Ahead of CTI Compliance Challenges

By focusing on these key components, you can ensure your hospice agency is prepared for an audit while maintaining high standards of care for your patients and families.

Have questions about hospice compliance or external audits? Let’s connect! I’d love to hear your thoughts or share additional resources that can help your organization succeed. Subscribe to this newsletter for more insights on hospice compliance, regulatory updates, and best practices. Feel free to share this with someone who might find it helpful! #HospiceExcellence #HospiceCompliance #Audits #SurveyReadiness #HospiceLeadership