We have a situation where our EMR is separating the arrival and time before a patient is pronounce and considering it an SIA visit. I feel that this is incorrect since upon arrival, we already know the patient had passed away. Sometimes it takes a nurse 10—15 minutes or more to get to patient to pronounce since families may be praying or someone is needing the nurse’s attention prior to entering the room. Does anyone know if this time is SIA billable? My EMR does, but we differ in opinion. We feel that if we received the call stating patient has passed away, that visit automatically is a post mortem visit.
As part of the introduction to the FY2016 final payment rule (which implemented the 2-tiered RHC payment system and the SIA) CMS commented:
Given that CMS intends to promote direct patient care in the 7 days prior to death, visits for the pronouncement of death will not be included as eligible visits for SIA payments.
Taken at face value, it does not sound as though CMS intends for that visit to be payable as an SIA visit. We do recognize that there are instances where family members believe that a patient has died but hospice staff arrive and find that the patient is still alive but dies shortly thereafter, but this doesn’t sound like it is one of those cases.
The citation is located in the first column on page 47175 at: https://www.gpo.gov/fdsys/pkg/FR-2015-08-06/pdf/2015-19033.pdf.