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June 23, 2021

Hospice and COVID-19 Testing (Revised)

This article is a revision to a previously published article titled “Hospice and COVID-19 Testing” and is intended to clarify the following points for nursing home residents:

  • Repeat Testing in Coordination with the Health Department, also referred to as Non-diagnostic testing of asymptomatic residents without known or suspected exposure to an individual infected with SARS-CoV-2 (apart from the initial testing referenced in the below CDC hyperlink), would be outside of the Medicare benefit and was not the focus of the original article. The intent of the original article was to address Medicare covered, "diagnostic testing" as defined by CMS and the CDC (https://www.cdc.gov/coronavirus/2019-ncov/hcp/nursing-homes-testing.htmlExternal Website).
  • Regarding diagnostic testing of Medicare beneficiaries that have elected the Medicare Hospice Benefit, hospices are required to have a process in place for communicating with non-hospice providers.The hospice Conditions of Participation at 418.56(e)set forth the requirements regarding the coordination of care, including that the care and services provided are based on all assessments of the patient and family needs; providing for and ensuring the ongoing sharing of information between all disciplines providing care and services in all settings, whether the care and services are provided directly or under arrangement; and providing for an ongoing sharing of information with other non-hospice healthcare providers furnishing services unrelated to the terminal illness and related conditions.
  • In order for a COVID-19 diagnostic testing to be paid as a hospice service, and therefore covered under hospice provider’s per diem payment rate, the hospice would have to determine whether such diagnostic testing is related to the terminal illness and related conditions.
  • The COVID-19 diagnostic testing must also be:
    • Provided or arranged by the hospice
    • Reasonable and necessary for the palliation and management of the terminal illness and related conditions.

In summary, while there may be circumstances under which the hospice would be responsible for coverage of the COVID-19 test it would be determined by the hospice on a case-by-case basis in accordance with identified hospice care needs. Hospices would, therefore, include such testing in the hospice plan of care and would have to either conduct the test or make arrangements for such test to be conducted.

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