This week’s You Asked... We Answered questions ask: "We hired an LPN with several years of experience with another hospice. We recently discussed death visits, and she shared that previously, she had made death visits and pronounced the person’s death. She was then instructed to document that she did all of that in collaboration with an RN. Based on the regulations, we were under the impression that the pronouncing part had to be done by an RN. If we document in collaboration, would that cover us in regards to that regulation?" and "Is it true when a patient comes into our Hospice Inpatient Unit (IPU), they would need to choose the hospice nurse practitioner as their attending physician in order for the hospice to bill for the IPU visits?"
We hired an LPN with several years of experience with another hospice. We recently discussed death visits, and she shared that previously, she had made death visits and pronounced the person’s death. She was then instructed to document that she did all of that in collaboration with an RN. Based on the regulations, we were under the impression that the pronouncing part had to be done by an RN. If we document in collaboration, would that cover us in regards to that regulation?
In the pronouncement of death rule it specifies that a physician may pronounce a person dead without personally examining the body of the deceased only if a competent observer has recited the facts of the deceased’s present medical condition to the physician, and the physician is satisfied that death has occurred. In this rule is specifies that an LPN is on the list of competent observers. The rule, however, does not say an RN can pronounce a person dead without personally examining the body.
An RN may pronounce the patient dead, according to the nursing law, if they are physically present with the patient. In these situations, the RN still has to notify the individual’s attending physician within 24 hours of the determination and pronouncement of death in order for the physician to fulfill the physician’s duties under section 3705.16 of the Revised Code.
LeadingAge Ohio would strongly caution against having the LPN contact the RN when the RN is not present to have the RN pronounce the person dead. This practice is outside of the RN’s scope of practice, and puts that RN’s license at risk. The LPN should contact the physician at the time of death and report the individual’s present medical condition to the physician.
Is it true when a patient comes into our Hospice Inpatient Unit (IPU), they would need to choose the hospice nurse practitioner as their attending physician in order for the hospice to bill for the IPU visits?
LeadingAge Ohio reached out to Palmetto GBA to ask their representative about billing for hospice nurse practitioner visits while a patient is in the hospice IPU.
Their response was:
“Services provided by Advanced Practice Registered Nurses (APRNs) cannot be billed unless they are designated as the patient’s attending physician. The patient would have to choose the APRN as their new attending physician.”
If you have a question you would like to see featured in You Asked/We Answered, email Anne Shelley, Director of Professional Development & HH/Hospice Regulatory Relations at ashelley@leadingageohio.org or Stephanie DeWees, Quality & Regulatory Specialist for Long Term Care at sdewees@leadingageohio.org.