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The OIG’s Hospice Portfolio

Thursday, August 9, 2018  
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The OIG’s Hospice Portfolio

By Roseanne Berry, MSN, RN

Reprinted with permission.


In July the Office of the Inspector General (OIG) released Vulnerabilities in the Medicare Hospice Program Affect Care and Program Integrity: An OIG Portfolio. The document is a synthesis of the “numerous evaluations and audits of the hospice program” conducted since 2005 and intended by the OIG to highlight “key vulnerabilities” and to make recommendations “for protecting beneficiaries and improving the program.”


The document zeros in on areas that the OIG believes negatively impact quality of care and program integrity and includes 15 recommendations to the Center for Medicare and Medicaid Services (CMS) to address them.  Although CMS concurred with only six of the fifteen, the OIG notes that they will continue to work toward implementation anyway.


The recommendations are organized into 7 broad areas:


1.       Strengthen the survey process to better ensure that hospices provide beneficiaries with needed services and quality care

2.       Seek statutory authority to establish additional remedies for hospices with poor performance

3.       Develop and disseminate additional information on hospices to help beneficiaries and their families and caregivers make informed choices about their care

4.       Educate beneficiaries and their families and caregivers about the hospice benefit 

5.       Promote physician involvement and accountability to ensure that beneficiaries get appropriate care

6.       Strengthen oversight of hospices to reduce inappropriate billing

7.       Take steps to tie payment to beneficiary care needs and quality of care to ensure that services rendered adequately serve beneficiaries’ needs, seeking statutory authority if necessary


Take the time to read the report and to consider the CMS response. It provides insight into the thinking of the OIG and hints on what may be coming next.  


Note that the OIG again draws distinctions between for-profit and non-for-profit hospices. When detailing the 43% growth in number of hospices between 2006 and 2006, they comment that the growth was due primarily to the for-profit sector and this sector had longer lengths of stay leading to a $4,000 higher per-beneficiary expenditure as well as higher frequencies of fraud. They describe a number of the schemes – knowingly admitting beneficiaries that are not eligible, billing for care never provided, and providing and billing for poor quality care.


The report goes on to describe a number of fraud schemes; beneficiaries not eligible and billing for services never provided.


What now?

1.       Read the portfolio in its entirely. You’ll find it here.

2.       Review your compliance program and your annual compliance work plan to see that it covers the risk areas from the OIG portfolio as well as any that are unique to your hospice.

3.       If you don’t have a comprehensive compliance program, you are putting your program at great risk, especially if you are a for-profit hospice.  Get on it now. 



more Calendar

From Referral to Admission: The Secret Ingredient to Compliant Growth (Webinar $149*)

The Denial Myth: Skillfully Working with Real or Perceived Denial (Webinar $149*)

Managing Hospice Live Discharge Part 1 - How, When & Why: Guidelines, Regulations & Report (*$149)

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