![\"\"](\"https:\/\/advantagehcconsulting.com\/blog\/wp-content\/uploads\/2018\/08\/problem_discipline.jpg\")
<\/p>\n<\/p>\n
Prepare for these actions focused on GIP, nursing facility patients, and more.<\/strong><\/em><\/span><\/p>\n The OIG has issued a fraud-fighting wish list for hospices, and many of the recommendations would make life much harder for legitimate providers.<\/p>\n A new report from the\u00a0HHS Office of Inspector General<\/strong>, Vulnerabilities in the Medicare Hospice Program Affect Quality Care and Program Integrity: An OIG Portfolio, reviews the watchdog agency\u2019s findings about the hospice industry going back more than a decade.<\/p>\n \u201cHospices do not always provide needed services to patients and sometimes provide poor quality care,\u201d the OIG says in a release. \u201cPatients and their families and caregivers do not receive crucial information to make informed decisions about their care. And taxpayers are bankrolling much of this poor care and fraud through the Medicare hospice benefit.\u201d<\/p>\n There\u2019s no doubt that hospice\u2019s growth has sparked so much interest from the fraud-fighting agency. Medicare paid $16.7 billion for 1.4 million hospice beneficiaries in 2016. That compares to $9.2 billion for fewer than 1 million beneficiaries in 2006, the OIG notes in the report summary.<\/p>\n The report works through a laundry list of hospice problems, ranging from upcoding to higher levels of care to cherry-picking financially lucrative patients to outright fraud.<\/p>\n The\u00a0National Hospice & Palliative Care Organization<\/strong>\u00a0cautions that \u201coutliers cited in the report do not adequately reflect the context of hospice care provision in the U.S.,\u201d according to a release. \u201cIncidents of deliberate fraud and abuse should be viewed separately from unintentional documentation or mathematical errors in an extraordinarily burdensome and complicated regulatory environment.\u201d<\/p>\n The OIG urges the\u00a0Centers for Medicare & Medicaid Services<\/strong>\u00a0to \u201cimprove the quality of care for beneficiaries and strengthen program integrity\u201d with these seven recommendations:<\/p>\n 1. Strengthen the survey process.<\/strong>\u00a0<\/span>Improvement would include using claims and survey data to target surveys. Surveyors could focus on hospices providing only one level of care, providers rarely providing physician services or care on the weekend, and those with repeat deficiencies.<\/p>\n 2. Establish additional remedies for hospices with poor performance.<\/strong><\/span>\u00a0Intermediate sanctions could be in hospices\u2019 future if CMS heeds this recommendation. Like HHAs, hospices would face sanctions including payment suspensions for new admissions and civil money penalties.<\/p>\n 3. Add more data to Hospice Compare.<\/strong>\u00a0<\/span>CMS should display claims-based and survey deficiency data on the website, the OIG urges. CMS already has finalized providing claims-based data in its 2019 payment rule, points out the\u00a0National Association for Home Care & Hospice<\/strong>.<\/p>\n 4. Educate beneficiaries, their families and caregivers about hospice.<\/strong><\/span>\u00a0Medicare should furnish more consumer-friendly resources via partners such as hospitals and caregiver groups.<\/p>\n 5. Promote physician involvement and accountability to ensure that beneficiaries get appropriate care.<\/strong><\/span>\u00a0The OIG urges \u201crequiring the hospice to obtain a physician\u2019s order to change the level of care to general inpatient care and including the ordering physician\u2019s National Provider Identifier on the hospice claim.\u201d In addition, \u201cthe hospice could also have the physician sign off on the level of care at reasonable intervals,\u201d as determined by CMS, during the GIP stay.<\/p>\n Why?<\/strong><\/span>\u00a0\u201cMaking the physician more accountable and requiring some record of the physician\u2019s involvement would help ensure that care is appropriate; it could also improve the quality of care,\u201d the OIG argues.<\/p>\n 6. Strengthen billing oversight.<\/strong><\/span>\u00a0CMS should use claims data analysis to target for audits providers with a heavy Skilled Nursing Facility and\/or Assisted Living Facility patient base; with a high percentage of lucrative patient diagnoses; that don\u2019t provide all levels of care; with a high level of GIP care for SNF patients; with lengthy GIP stays; and those with high levels of payment for Part D drugs for their patients.<\/p>\n 7. Take steps to tie payment to beneficiary care needs and quality of care.<\/strong><\/span>\u00a0CMS should base payment on a patient\u2019s care needs \u2014 presumably through a case mix system \u2014 and place of residence (nursing home), the OIG urges.<\/p>\n What the OIG neglects to mention in this report is underutilization of hospice care, NHPCO maintains. Data show that 28 percent of beneficiaries received care for only seven days or less in 2016, the trade group points out. \u201cLike intentional fraud, this is unacceptable.\u201d<\/p>\n CMS rejects more than half of the OIG\u2019s hospice recommendations, and \u201cwe generally agree,\u201d NHPCO points out. But you can bet many of these program integrity strategies will eventually make it into practice, observers predict.<\/p>\n \u201cA number of the areas are under scrutiny by one or more oversight entity, including the OIG, CMS, Medicare Administrative Contractors (MACs) and others,\u201d NAHC highlights.<\/p>\n Take action:<\/strong>\u00a0<\/span>\u201cIt is advisable that hospices examine their admission, care planning, and care processes with the OIG\u2019s recommendations in mind to ensure that eligible hospice patients are receiving all hospice benefit services that are appropriate for the treatment of their terminal condition and any related conditions,\u201d NAHC urges in its member newsletter.<\/p>\n Meanwhile, \u201cwe look forward to working with the Administration to simplify and streamline the hospice benefit and compliance process and to ease the governmental red tape in order to encourage honest and law-abiding hospice providers while protecting the public from unacceptable intentional abuse,\u201d NHPCO says. \u201cThis includes \u2026 to focus government efforts on truly abhorrent providers and spare compliant programs from needless and duplicative investigation.\u201d<\/p>\n Note: The report is at\u00a0https:\/\/oig.hhs.gov\/oei\/reports\/oei-02-16-00570.pdf<\/a>.<\/p>\n Source- SuperCoder<\/span><\/i><\/a><\/p>\n","protected":false},"excerpt":{"rendered":"