Returning Medicare and Medicaid Overpayments – Better Act Fast!

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. 

By | 2017-05-17T09:21:39+00:00 August 24th, 2015|Comments Off on Returning Medicare and Medicaid Overpayments – Better Act Fast!

The 2016 Hospice Wage Index Proposed Rule – Some Thoughts

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).

By | 2017-05-17T09:21:44+00:00 June 25th, 2015|5 Comments

The Physician Narrative Attestation: Beware of the Not-So-Fine Print

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. 

By | 2017-05-17T09:21:48+00:00 May 21st, 2015|Comments Off on The Physician Narrative Attestation: Beware of the Not-So-Fine Print

Hospice Prognosis vs Diagnosis – Can we slow down for a minute please?

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!"

By | 2017-05-17T09:21:51+00:00 April 3rd, 2015|17 Comments

The Hospice Times They Are A-Changin….

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.

By | 2017-05-17T09:21:53+00:00 February 15th, 2015|6 Comments

Part II. Appreciative Inquiry and the Certification Process…Imagine That! Discovery and Dream

Normal 0 false false false EN-US JA X-NONE /* Style Definitions */ table.MsoNormalTable {mso-style-name:"Table Normal"; mso-tstyle-rowband-size:0; mso-tstyle-colband-size:0; mso-style-noshow:yes; mso-style-priority:99; mso-style-parent:""; mso-padding-alt:0in 5.4pt 0in 5.4pt; mso-para-margin:0in; mso-para-margin-bottom:.0001pt; mso-pagination:widow-orphan; font-size:12.0pt; font-family:Cambria; mso-ascii-font-family:Cambria; mso-ascii-theme-font:minor-latin; mso-hansi-font-family:Cambria; mso-hansi-theme-font:minor-latin;} Years of experience and research have demonstrated that “…people learn, and organizations change most readily when they focus on, study, and engage in dialogue about strengths, patterns of success and who they are at their best."

By | 2017-05-17T09:22:01+00:00 December 17th, 2014|1 Comment

Part III. Appreciative Inquiry and the Certification Process…Imagine That! Design and Destiny

Through collaborative thinking, the team chooses innovative processes that are in alignment with both the strengths identified in Discovery and the imagined hopes of the future (Dream).  

By | 2017-05-17T09:22:04+00:00 December 17th, 2014|Comments Off on Part III. Appreciative Inquiry and the Certification Process…Imagine That! Design and Destiny

Part 1: Appreciative Inquiry and the Certification Process… Imagine that!

Every hospice physician has experienced difficulties in assessing “gray” patients. These are the ones who, at admission, do not have a principal diagnosis or terminal story that leaps out from the record, although for many of these patients, the physician is able to answer “no” to the “would you be surprised if your patient dies within the next six months” question. 

  • Are these patients truly terminally ill?
  • Is a period of seeming stabilization sustainable?
  • Should these patients be evaluated for discharge due to extended prognosis?


By | 2017-05-17T09:22:07+00:00 November 27th, 2014|3 Comments

In Hospice, Every Day is Election Day

What does hospice have in common with political campaigns besides elections? Unfortunately, more than you'd think. It's not to late to reverse course and return to the days when journalists, patients/families, and referring physicians were promoting the benefits of hospice. Our colleague Kathy Brandt explores these similarities and ways each hospice can work to repair the reputation of hospice.

By | 2017-05-17T09:22:10+00:00 October 30th, 2014|Comments Off on In Hospice, Every Day is Election Day

Back to the “Definition Board:” Defining Terminal Illness

The Medicare Hospice Benefit has always defined the terminal illness, not as a single diagnosis, but as the interplay of conditions that together cause an individual to have a prognosis of 6 months or less.  At this point, the proposed definition is open for comments. However, my guess is that in the final determination there may well be a clear differentiation between the definition of ‘terminal illness’ and that of the ‘principle/hospice-qualifying diagnosis’ to better underscore the prognostic implication and comprehensive nature of the former.

By | 2017-05-17T09:22:11+00:00 October 20th, 2014|1 Comment