Introduction Here is the conundrum: A hospice clinician makes an error (she did not provide patient education on proper use of oxygen in the home because she thought the DME company provided it). Her error/omission resulted in an adverse patient outcome (patient smoked while using oxygen and set himself and surroundings on fire). Even though [...]
As the hospice industry becomes increasingly competitive and challenging, especially with upcoming transparency meant to highlight quality, hospices are asking how they can set themselves apart. Hospices are continuing to look for ways to demonstrate quality within their communities and as they form strategic partnerships. Utilizing the Malcolm Baldrige National Quality Award criteria and framework [...]
It’s that time of year again when the blooming landscape and longer days inspire a thoughtful inspection of how well our homes are in order. As we know, it is not uncommon during this process to stumble upon some areas of wear and tear that need fixing (e.g., broken gutters, missing shingles, clogged vents, the [...]
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 [...]
Recently, one of Weatherbee’s senior consultants observed a hospice’s interdisciplinary group (IDG) meeting as part of an on-site mock survey of the organization. The 4-hour meeting included a review of all deaths and admissions that occurred during the prior 2 weeks, as well as a review of all existing patients on the hospice’s census. A total of 30 patients were discussed. The medical director, 4 registered nurses (RNs), 2 social workers, a chaplain, and the volunteer coordinator were present during the meeting.
In the midst of tremendous challenges facing the hospice industry, the Centers for Medicare and Medicaid Services (CMS) has issued guidance to Medicare Administrative Contractors (MACs) and Qualified Independent Contractors (QICs) that is likely to have a positive effect on hospice providers. The guidance from CMS directs MAC and QIC reviewers to limit the redetermination and reconsideration review to the reason(s) the claim was initially denied for all post-payment reviews.
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).
Last year, a hospice medical director in Pennsylvania, was convicted of Medicare fraud for false certifications of the clinical eligibility of patients for hospice care. The wrongdoing involved appears to be fairly black and white. However, another more nuanced area of regulatory oversight of physicians is looming on the horizon.
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!"