Home Health & Hospice Week

Watch out for tight turnaround.

Since a big chunk of your Special Focus Program score will rely on survey results, it’s important that they are accurate. That may be hard to assure given surveyor variability and other issues, but one new mechanism will help with the endeavor.

The Centers for Medicare & Medicaid Services has finalized adopting the informal dispute resolution process for hospices as proposed. Under IDR, hospices can “address disputes related to condition-level survey findings following a hospice program’s receipt of the official survey Statement of Deficiencies and Plan of Correction, Form CMS–2567. The proposed IDR for hospices would be similar to the process already in existence for home health agencies,” CMS explains in the 2024 home health final rule published in the Nov. 13 Federal Register.

This will be very important under the SFP, because CLDs will count toward a hospice’s score under the program (see related story, p. 324). The bottom 10 percent of performers will be posted publicly, while the bottom 1 percent will undergo SFP inclusion including extra surveys and potentially door-closing consequences.

Hospices will have 10 calendar days from receipt of the 2567 to file an IDR request, a CMS speaker detailed in the agency’s Nov. 14 forum on IDR and the SFP. That’s the same amount of time they have to submit a plan of correction, CMS notes in the final rule. The request must “include the specific survey findings that are disputed,” the rule indicates.

CMS hasn’t yet set a deadline for a return decision on the IDR request.

Not included: Note that hospices will not be able to use IDR to appeal either SFP selection or survey enforcement actions, such as payment suspensions and civil money penalties.

Watch for: CMS will issue more specific IDR instructions in a forthcoming update to the Medicare State Operations Manual Chapter 10, a CMS speaker indicated in the forum.