Thoughts on OIG Report on Hospice Inpatient Care

The HHS Office of Inspector General report on the use and misuse of hospice inpatient care in the Medicare Hospice Benefit, that was released on March 31, 2016, was undertaken as part of an ongoing effort at OIG to prevent inappropriate claims for hospice general inpatient care (GIP), including care being billed but not provided and beneficiaries receiving care they do not need.

As the oldest and largest leadership organization representing hospice and palliative care providers and professionals, NHPCO continues to welcome appropriate oversight of the field and works continually with its members to ensure their awareness of and compliance with all hospice related rules and regulations. NHPCO has also worked closely with Congress and CMS to promote policy changes that stem the abuses referenced in the report, and ensure a high quality hospice experience for consumers. Specifically, NHPCO recommends that hospices:

• Have a process and procedure for determining eligibility for the GIP level of care, that they document the reasons that GIP is appropriate for each patient, and evaluate continued eligibility for GIP EVERY DAY with documentation in the medical record that can be easily reviewed.
• Obtain a written physician order for a change in level of care. 
• Review use of GIP and the length of stay for each patient at the GIP level of care on a monthly basis, with documentation about the review in each patient’s medical record. 
• Review the development of plans of care for patients admitted to and continuing in the GIP level of care.
•  Develop a process for reviewing all medications, check and double check how medications are paid for and ensure that contract providers are billing appropriately.
• Review and update your processes at inpatient facilities to ensure daily evaluation of eligibility, detailed documentation to prove continued eligibility and accurate and complete care plans. 

NHPCO will continue to work with member organizations, policymakers, and other stakeholders to ensure that hospice claims are billed appropriately, and that beneficiaries experience high quality, compassionate care at the end-of-life.

See NHPCO's Regulatory Alert on the new OIG report.

Call to Action: Contact legislators to support hospice

All supporters of hospice care in the U.S. are encouraged to contact their legislators July 14 through 16, 2015, as part of the hospice community's annual legislative event on Capitol Hill.

On July 14, nearly 300 Hospice Advocates, representing 48 states and districts, and every discipline in the Interdisciplinary Team, are in Washington, DC, visiting more than 400 Congressional offices to call for support of hospice.

Individuals across the country also can make a tangible difference for hospices by participating from their homes across the nation. Hospice Action Network and NHPCO are encouraging all hospice supporters to call their Members of Congress and take specific actions that will not only benefit the hospice community but allow hospices to better serve the people for which they care.   

Advocates will be asking their Senators to support The Care Planning Act of 2015 (S 1549) designed to give people with serious illness the freedom to make more informed choices about their card, and the power to have those choices honored. Additionally, Senators will be asked to join the Sign-on Letter written by Senators Roberts and Warner that calls for CMS to test hospice payment changes that were included in the FY2016 Notice of Proposed Rulemaking.

Members of the House of Representatives will be asked to co-sponsor The Hospice Care Access Improvement Act of 2015 (HR 3037) that was just introduced yesterday, July 13, 2015. This legislation calls for a one year testing period to ensure any payment methodology reforms proposed by CMS will be implemented with minimal unintended complications or consequences. The opportunity to test any system changes and conduct the necessary education and training would benefit CMS and the hospice provider community. The legislation also contains a number of program integrity provisions long-supported by the hospice community.

The Hospice Action Network has created an easy to use online "Click to Call" Campaign that will help people understand the issue and then connect them to their Congressional representatives. The whole process should take no longer than 30 minutes, start to finish- that’s all it takes for you to make a difference.

My first observation

I'm touched by the way the lovely Latino woman at the donut store calls me "Honey" and tells me to have a nice day when she hands me my iced coffee. It's completely authentic and caring and it touches me.  So as today starts, that's one thing I'm thanking for - not just the kind woman but the warmth she gives me with my iced coffee.