Traditional hospice transactions are receiving increased regulatory scrutiny and headwinds. Amidst these challenges, many hospices are considering management services organizations as an alternative to traditional...more
An effective compliance program is the bedrock of any successful healthcare organization and behind every successful compliance program is a trusted relationship between the Compliance Officer and CEO. In this episode, Husch...more
Centers for Medicare & Medicaid Services (CMS) devised a “Special Focus Program” to identify poor performing hospices and help them improve through more frequent surveys and technical assistance. CMS would also impose...more
For a variety of unfortunate reasons, some hospices found themselves facing a 4% rate reduction for non-compliance with either Hospice Item Set (HIS) or Consumer Assessment of Healthcare Providers & Systems (CAHPS)...more
CMS has criticized hospices for underutilizing general inpatient care (GIP) but has also specifically targeted GIP claims for audit and medical review. In addition to CMS’s standard tools for reviewing GIP claims, such as...more
Join Husch Blackwell’s Meg Pekarske and Wendy Arends as they explore the new draft Merger Guidelines and what enforcement may look like in the future. Given the number of hospices looking to consolidate through mergers, joint...more
While not new, the number and scope of Targeted Probe and Educate (TPE) reviews have soared to new heights. At the same time, more hospices are facing the uncomfortable position of moving to a second and sometimes third round...more
In the midst of consolidation and restructuring among hospices, the Centers for Medicare & Medicaid Services (CMS) is scrutinizing initial enrollments and changes in ownership and management. In this episode, Husch...more
It’s been hard to keep track of all the new changes related to government oversight of hospices. This growing list now includes an expansion of the 36-month rule to hospices, which will limit the frequency that hospices can...more
Hospices have been the target of increased government scrutiny in 2023, and the Centers for Medicare and Medicaid Services (CMS) is planning to take further aim in 2024 through surveys. Join Husch Blackwell’s Meg Pekarske,...more
Hospices are increasingly looking to buy, consolidate, or merge to achieve administrative efficiencies and expand operations for growth. A common approach among nonprofit hospices is to combine through a member substitution....more
A study published by NORC at the University of Chicago, a nonpartisan research organization, concluded that the Hospice Benefit saved Medicare $3.5 billion in 2019. The data behind that figure, and the study’s related...more
In the five-step audit appeals process, hospices often stop their appeal efforts after finding success at the third step, a hearing before an administrative law judge (ALJ). However, if an ALJ issues an unfavorable decision,...more
In this episode, Husch Blackwell’s Meg Pekarske and Jonathan Porter, a former federal prosecutor, discuss takeaways from the recent American Bar Association’s Annual National Institute on Health Care Fraud. Most importantly,...more
Hospice professionals are often left wondering how the Centers for Medicare and Medicaid Services (CMS) and other government entities identify enforcement priorities. They also seek understanding about the subsequent steps...more
Audits that employ statistical extrapolation can turn a handful of claim denials into a liability of hundreds of thousands or millions of dollars. After years of relative quiet, the statisticians are back. The Centers for...more
Earlier this spring, as part of its annual rulemaking process for hospices, the Centers for Medicare and Medicaid Services (CMS) issued several important regulatory proposals. In addition to the yearly update in hospice per...more
The HIPAA regulations require that covered entities enter into agreements with business associates who provide certain services for the covered entity involving the receipt, use, or disclosure of protected health information....more
The U.S. Department of Health and Human Services’ Office of Inspector General (OIG) reported in November 2022 that many providers are not complying with Medicare’s billing rules for advance care planning services. In large...more
Payment suspension and overpayment extrapolation are among the most extreme and effective enforcement tools available to the Centers for Medicare and Medicaid Services (CMS) and its auditors. However, even these measures can...more
The Centers for Medicare and Medicaid Services (CMS) unexpectedly proposed a rule change that could have a significant impact on how hospices investigate compliance issues and take remedial action. The rule change directly...more
The Home Care 100 Leadership Conference is an annual gathering of top leaders and innovators in the hospice and home health community. Presentations and informal discussions address the current state of the industry and what...more
While direct patient billing may be less common for hospice patients than for patients receiving hospital or other types of care, there are aspects of the No Surprises Act and its implementing regulations that are important...more
Recently, there has been an uptick in contractor participation at the ALJ stage of hospice audit appeals. This development poses unique challenges and new advocacy opportunities for providers. In this episode, Husch...more
The Department of Health and Human Services Office of the Inspector General (OIG) recently released a report detailing its evaluation of CMS’s primary fraud, abuse and waste investigators—the Unified Program Integrity...more