Home Health & Hospice Week

Home health survey rate expected to bottom out at 65% this year.

Oversight efforts are much on policymakers’ minds, according to the latest budget proposal from the Biden administration.

Hospice supervision comes up in a number of ways in the administration’s budget released on March 11. Both White House and Health and Human Services budget documents focus on surveys and the Special Focus Program, for example.

“The budget requests $492 million for Survey and Certification, an increase of $85 million or 21 percent above FY 2023,” HHS says in its “Budget in Brief” document. “Survey and certification funding has remained relatively flat since FY 2015, which over time has limited the program’s capacity to perform standard initial, recertification, and validation surveys,” it laments.

HHS spends a lot of space talking about nursing home surveys, but hospice surveys are a priority too, it indicates in its budget justification document for Congress. In 2022, the most recent year with data, the Centers for Medicare & Medicaid Services surveyed 87.1 percent of hospices within the required 36-month timeframe.

HHS aims to get that back up to 98 percent. (“Although the CMS target is 100 percent compliance with the statutory requirement, the stated measure represents a realistic expectation, considering the effort required at the state-level to achieve the survey interval timeframe requirement,” HHS explains in the justification document.)

CMS expects to complete 1,170 hospice surveys this year, plus 50 hospice Special Focus Program surveys, HHS indicates in the justification document.

Can Surveyors Keep Up With The SFP?

Overall, “CMS indicates in many places in the budget documents that they are struggling with survey backlogs, primarily amongst state survey agencies (SSAs), and mostly as a result of both lingering COVID impacts and multi-year stagnant funding from Congress for survey & certification activities,” notes the National Association for Home Care & Hospice in its budget analysis.

Problem: “Given that hospice surveys are such a critical component of the SFP algorithm, it is important that CMS use accurate and up-to-date survey data,” NAHC points out. “However, the budget language here seems to indicate that CMS is not caught up on the hospice survey backlog, and may not be able to ensure that all hospices have indeed been surveyed in the last 36 months for at the near future,” the trade group warns in its rule analysis. That could prove a reason to delay SFP’s start date, critics say.

On the home health side, CMS expects to complete only 65 percent of required home health agency surveys within the 36-month timeframe this year, HHS reveals in the document. That would go up to 85 percent if the survey budget is fully funded as requested in 2025.

Surveys aren’t the only oversight providers face. “In FY 2023, the UPICs initiated Medicaid provider investigations and audits in collaboration with 49 state Medicaid agencies,” HHS indicates in its justifications document. Hospices are in the group of most commonly reviewed providers for Unified Program Integrity Contractors, HHS says.

And hospices continue to make up one of CMS’ “four driver service areas” leading to high Medicare improper payment rates, HHS highlights in the document. That’s despite the fact that “the improper payment estimate for hospice claims decreased from 12.04 percent in RY 2022 to 5.36 percent in RY 2023,” HHS points out (see more Comprehensive Error Rate Testing program details at HHHW by AAPC, Vol. XXXIII, No. 1). “Insufficient documentation is the major error reason for hospice claims. The primary reason for these errors is missing or insufficient documentation to support the certification or recertification,” the agency relates.

CMS is using “targeted probe and education efforts … automation, billing reviews, and the fraud prevention system to address improper payments,” HHS adds.

Note: The 327-page HHS budget justification document is at www.cms.gov/files/document/fy2025-cms-congressional-justifi­cation-estimates-appropriations-committees.pdf.