1 Medicare says it paid twice for some hospice-beneficiary services, supplies, and medications. Hospice providers must cover “virtually all” care needed by the terminally ill individual. In the 2017 Hospice Proposed Rule, the Centers for Medicare and Medicaid Services (CMS) says that medically necessary services unrelated to a hospice beneficiary’s terminal prognosis are “unusual and exceptional.” After studying non-hospice Medicare spending on hospice beneficiaries for several years, CMS suspects “unbundling of services that perhaps should have been provided and covered under the Medicare hospice benefit.” CMS cites three possible conclusions. Hospice agencies are not covering all hospice beneficiary healthcare costs due to: wrongly classifying comorbid conditions as unrelated to the terminal prognosis, poor communication that results in non-hospice providers administering treatment for conditions related to beneficiaries’ terminal prognoses during hospice election, or intentional exclusion of treatment to avoid costs.
2 CMS is exploring whether some hospice agencies use the hospice benefit as a long-term, custodial care solution for patients ineligible for CMS home health services. On cue from the Office of the Inspector General (OIG), CMS is investigating whether hospices target
beneficiaries with diagnoses that typically decline slowly (think neurological, like Alzheimer’s Dementia and Parkinson’s Disease) “because they may offer the hospices the greatest financial gain.” CMS continues analyzing data from hospice claims and cost reports with an eye toward tighter regulatory requirements “to reform and strengthen the Medicare hospice benefit.”
3 Near-death hospice services are being scrutinized.On any given day during the last seven days of a hospice patient’s life, few (9%) received a social worker visit. On any one of those same last seven days, only about half (51%) received a nurse visit. CMS compiled those facts from hospice claims data that agencies submitted for care provided during fiscal year (FY) 2014. The Journal of the American Medical Association (JAMA) crunched the numbers for FY 2014 a bit differently. CMS says JAMA reported 81,478 (12.3 %) hospice decedents received no professional staff visits in the last two days of life. To ensure that “beneficiaries and their families and caregivers are, in fact, receiving the level of care necessary during critical periods such as the very end of life,” CMS hired a contractor to monitor hospice claims in real time to identify hospice program vulnerabilities and potential fraud and abuse areas.
In the world of hospice care, change is the new norm. On April 21, 2016, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that would update 2017 Medicare payment rates and the wage index for hospices serving Medicare beneficiaries. Here are five essential facts you need to know!
4 HIS is going Clinical. The Hospice Item Set (HIS) will morph into part of a standardized comprehensive assessment performed at each hospice beneficiary’s admission. CMS asks for comments from the hospice industry on “a potential hospice patient assessment tool that would collect both quality, clinical, and other data with the ability to be used to inform future payment refinement efforts.” Currently, only HIS and hospice claims data are available to CMS and its contractors to inform quality and payment issues. “A hospice patient assessment tool would allow us to gather more detailed clinical information, beyond the patient diagnosis and comorbidities that are currently reported on hospice claims,” CMS says in the 2017 Hospice Proposed Rule.
for patient survey reports. CMS proposes two new quality measures, reportable no sooner than April 1, 2017. Hospice Visits When Death is Imminent will measure clinical (physician, registered nursing, nurse practitioner, and physician assistant) visits during
the last two days of life, and any other hospice visits during the last seven days of life. Hospice and Palliative Care Composite Process Measure will assess whether agency care processes are consistent with guidelines, based on six measures currently part of the Hospice Item Set (HIS).
About the authorBeth Noyce, RN, BSJMC, COS-C, HCS-D, provides consulting, education, and auditing services to hospice and home health agencies, and affordable instant in-services for agencies at noyceconsulting.com. She has presented at UHPCO, NAHC, UAHC, DecisionHealth’s Coding summit, and other seminars, and has educated and mentored clinicians at multiple agencies in clinical documentation, CMS coverage issues, diagnosis coding, HIS, OASIS, and regulatory compliance. She has served as a MAC medical reviewer. Her work with DecisionHealth includes publishing in Diagnosis Coding Pro, helping edit the ICD-9 Coding Manual, authoring multiple ICD-10 courses, editing updates for the HCS-H credential study guide and writing other study guide.
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“A hospice patient assessment tool would allow
us to gather more detailed clinical information, beyond
the patient diagnosis and comorbidities that are
currently reported.”The 2017 Hospice Proposed Rule
Let’s take a Glimpse Into the Future of HospiceThis exclusive, free webinar with Beth Noyce, RN, BSJMC, COS-C, HCS-D will give you a detailed look at the 2017 Hospice Proposed Rule. Stay informed about the future of your industry!
