For the last several years CMS has identified concerning hospice industry trends in various studies and payment updates. Among the issues identified are long-lengths of stay, live discharges, skilled visits in the last days of life, compliance with hospice coding guidelines, non-hospice spending, utilization in the four levels of care and related versus unrelated decisions. Hospice spending has risen at rates significantly faster than the increase in beneficiaries served. Consider the specific areas of concern identified in the latest OIG Workplan:
- Medicare Payments made outside the Hospice Benefit (Non-hospice spending).
- Duplicate drug claims for Hospice beneficiaries.
- Trends in Hospice survey deficiencies and complaints.
- Frequency of skilled nurse on-site visits to assess the quality of care and services.
- Compliance with Medicare Requirements – Hospice Medicare Benefit Policy Manual.
- Medicare Hospice payments for chronic care management
- Protecting Medicare Hospice beneficiaries from harm
Hospice providers, this is a heads up! We are surveyed every three years (IMPACT Act), documentation and billing compliance will be probed (Targeted Probe and Educate) and the OIG has specific areas of concern that will be reviewed and monitored. Hospice compliance with the regulations is and will continued to be tested with the number one risk area relating to documentation of Eligibility of the beneficiary to qualify for payment under the Medicare Hospice Benefit.
At S.M.A.R.T. Healthcare Compliance Resources we are equipped to help our current and future clients comply with Medicare Regulations therefore maintaining their hard-earned reimbursements.