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.
OIG Hospice Audit – Despite Extremely Low Error Rate, OIG Claims Significant Refund Liability on Basis of Extrapolation
The OIG clings to its tenuous position that, even with its concession that CMS will determine the overpayment amount, the hospice was overpaid “at least $447,467.” This suggests OIG is driven to show Congress that it will continue to “come down hard” on hospices, even those with very low error rates.
With a heavy heart I read the latest Washington Post article lambasting the hospice industry for not providing the higher levels of care: continuous care and general inpatient (GIP) when patients need it. Citing numerous examples, and naming specific hospices at fault, this latest investigative reporting by the Washington Post continues its general thesis from a previous article last December: the hospice industry, dominated by for profit providers, is doing a lousy job.
Developing a consistent program for auditing your clinical records is critical in ensuring you are mitigating your risk of non-compliance and ultimately non-payment.
Like so many other areas in hospice, the general inpatient level of care (GIP) is coming under increased scrutiny by the Department of Health and Human Services (HHS), Office of the Inspector General (OIG) and the Centers for Medicare and Medicaid Services (CMS). The OIG is currently conducting a series of studies and audits on the GIP level of care.
The OIG continues to recommend that CMS increase the frequency of hospice recertification surveys. On August 29, 2013 the OIG published a new hospice report (OEI-06-13-00130) entitled the Frequency of Medicare Certification Surveys is Unimproved.