These are a few of the headlines and articles generated by the most recent OIG report entitled: Hospices Should Improve Their Election Statements and Certifications of Terminal Illness published September 15, 2016. Beginning with the leader in negative hospice hysteria, the Washington Post’s Peter Whoriskey (yes, that guy again), the relatively benign and definitely limited findings of [...]
Don’t shoot the messenger but compliance with Medicare and Medicaid rules just got tougher for hospice organizations. In the first judicial opinion on when a Medicare or Medicaid “Overpayment” is “identified” for purposes of the Affordable Care Act’s (ACA) 60-Day Repayment Law, a New York federal court’s interpretation complicates the already difficult task providers face in having sufficient time to assess and quantify potential overpayments.
I have been thinking a lot about the FY 2016 Hospice Wage Index proposed rule (NPRM). The more I have thought about it, however, the more complex it seems. I have needed to harken back to my salami methodology (described here) and try to break it down into manageable chunks. The only chunks I am focusing on are the ones having to do with payment reform (tiered reimbursement and the Service Intensity Add-On) and the "clarification" to include all diagnoses on claim forms (and the related - excuse the pun - virtually all / related and not related / prognosis vs diagnosis conundrums).
I had not been paying much attention to NHPCO's flurry of activity during March regarding prognosis vs. diagnosis until I received an email from a well-respected hospice CEO that said, in part:
"Our Medical Director is livid and is adamant that what 'influences' the prognosis is very different from what is "related to" the prognosis. This seems like a fundamental shift from what we have been doing for thirty years - is it possible that everyone (including NHPCO) has been so wrong about this? We think we have financial challenges now - just wait!"
One of my favorite nuns in high school often called me "bold" (a frequent nun term) and accused me of taking too much pleasure in "starting revolutions." For this blog post, allow me to be bold and describe a revolution I see occurring in the hospice industry. I did not start it, I don't even take pleasure in it - but I want to name it.
Am I a party pooper? A Debbie Downer? You can decide, but I don't think the hospice provisions in the Impact Act of 2014 are going to do much to increase transparency, sort out the "good" hospices from the "bad," or, sadly, improve the quality of care provided by hospices. Let me explain...
If we don't count today or weekends, there are only 17 full work days left until the July 1, 2014 implementation deadline for the Hospice Item Set (HIS). This is getting really serious.
I have had the opportunity in the past week to take my HIS show on the road to two State hospice organizations (Massachusetts and New Jersey). The most important thing I learned from attendees at both 3 hour workshops is that there has been very little information provided by EMR (electronic medical records) vendors with regard to the HIS support that they will/will not be providing to their customers.
For many hospices and other non-profits, fundraising is a “necessary evil.” It is something to slog through in order to be able to continue to provide wonderful services. Hospices need to raise funds, but relegating fundraising to second-class status makes securing enough funding more difficult than it needs to be.
I love that expression: "in the weeds." It has entered into the realm of jargon but, nevertheless, it so clearly describes how I have been feeling with the HIS implementation guide I have been writing with Melanie Merriman. Thoroughly in the weeds with the HIS -trying not to get choked, trying to sort through the gazillion details, trying to pull out the non-essential and get to the heart of the matter.
I have been giving a lot of thought to hospice quality this week for two reasons: 1) I am still working on the Hospice Item Set: A Step by Step Implementation Guide (shameless plug, but we are nearly done!); and 2) I am still reeling from the horrific comments about negative hospice experiences in the comments section of the most recent Washington Post hospice diatribe. The resulting feeling is one of frustration and worry.