Warning: Your own data will land you under reviewers’ microscope.
Medicare’s proposed rule for 2017 hospice payment may contain some big changes such as new quality measures and a new OASIS-like assessment tool on the horizon. But the most difficult challenge is likely to be the scrutiny hospices will be under for regulatory and compliance hot spots, the Centers for Medicare & Medicaid Services indicates.
Good news: Some of the big hospice data points CMS and its contractors are tracking have gone down, points out Judi Lund Person with the National Hospice & Palliative Care Organization. For example, these figures have all decreased: percentage of claims with only one diagnosis; nonhospice spending for hospice patients; Part D spending on drugs for hospice patients; and live discharges (see specific stats, p. 208).
Bad news: But it appears to be too little, too late. CMS spends a big chunk of the proposed rule outlining its concerns with various areas and warning hospices that it will be monitoring the data and planning related action.
“The greatest risk for hospice agencies … is not necessarily one of the proposals in the rule, but rather the warnings from CMS that it suspects certain hospice providers of engaging in widespread fraudulent activity,” says RN Beth Noyce with Noyce Consulting in Salt Lake City.
Watch out: Providers whose data sticks out in CMS’s areas of concern will most likely “eventually face provider-specific reviews,” Noyce expects. “My concern is that much hospice clinical documentation may not pass muster under medical review.”