Home Health & Hospice Week

Expect related services to go under the watchdog agency’s microscope.

The feds don’t plan to let up on hospice oversight any time soon, as evidenced by the HHS Office of Inspector General’s newly released Work Plan for 2017. Will your practices surrounding these newly announced hot spots pass muster?

The OIG has added three new hospice areas to its blueprint for work next year, notes law firm Cooley in analysis on its website. The topics are:

1. Medicare Hospice Benefit Vulnerabilities and Recommendations for Improvement: A Portfolio. The Medicare hospice program has an array of “vulnerabilities in payment, compliance, and oversight as well as quality-of-care concerns,” the OIG warns. “We will summarize OIG evaluations, audits, and investigative work on Medicare hospices and highlight key recommendations for protecting beneficiaries and improving the program.”

2. Review of Hospices’ Compliance with Medicare Requirements. The OIG also includes this rather vague and wide-ranging topic, although the summary does hint at delving into services billed separately from the hospice benefit. “When a beneficiary elects hospice care, the hospice agency assumes the responsibility for medical care related to the beneficiary’s terminal illness and related conditions,” the OIG points out.

3. Hospice Home Care — Frequency of Nurse On-Site Visits to Assess Quality of Care and Services. The hot button topic of visit utilization shows up on the OIG’s to-do list. “Medicare requires that a registered nurse make an on-site visit to the patient’s home at least once every 14 days to assess the quality of care and services provided by the hospice aide and to ensure that services ordered by the hospice interdisciplinary group meet the patient’s needs,” according to the Work Plan. “We will determine whether registered nurses made required on-site visits to the homes of Medicare beneficiaries who were in hospice care.”

Reminder:Anew quality measure on skilled service visits in the last days of life was just finalized in the 2017 hospice payment update final rule.

Review: The OIG also points to its report issued in September on Notices of Election and Certifications of Terminal Illness, in which the Centers for Medicare & Medicaid Services agreed to issue model NOE language (see Eli’s HCW, Vol. XXV, No. 35).

Takeaway: “Carefully review the Work Plan to determine areas of government focus,” counsels Cooley attorney Sarah DiFrancesca in the analysis. “The Work Plan often serves as a useful resource for companies planning and prioritizing compliance activities for the upcoming year, including training, auditing and monitoring.”