Catherine Boerner (cboerner@boernerconsultingllc.com) is President of Boerner Consulting LLC in New Berlin, WI.
There is much activity around hospice audits and extrapolating samples. It is important to review these audit reports and understand the focus of where some of these findings have been reconsidered and changed.
You can find the letters from some law firms within these reports stating, for example:
In sum, the OIG’s [Office of Inspector General] IMRC [Independent Medical Review Contractor] reviewers, and by extension the OIG, applied the wrong legal documentation standard as to what the Medicare hospice benefit requires to support a terminal prognosis and support a claim for hospice services that were indeed furnished. OIG’s Draft Report does not contend services were not furnished; nor does the Draft Report contend, because it cannot, that the hospice physicians failed to certify in good faith that each patient had a terminal prognosis for each hospice benefit period under review.[1]
Announced or revised |
Agency |
Title |
Component |
Report number(s) |
Expected issue date (FY) |
---|---|---|---|---|---|
Completed (partial) |
Centers for Medicare & Medicaid Services |
Review of Hospices’ Compliance with Medicare Requirements |
Office of Audit Services |
A-02-16-01023; A-02-16-01024; A-02-18-01001; A-09-18-03016; A-09-18-03017; A-09-18-03028; A-09-20-03034; A-09-20-03035; A-09-18-03024; A-09-18-03009; W-00-16-35783; W-00-18-35783; various reviews |
2022 |
There are additional reports referenced to assist with understanding where OIG is finding errors during these audits.
Report title |
Report number |
Date issued |
---|---|---|
Safeguards Must Be Strengthened to Protect Medicare Hospice Beneficiaries From Harm |
OEI-02-17-00021 |
7/3/2019 |
Hospice Deficiencies Pose Risks to Medicare Beneficiaries |
OEI-02-17-00020 |
7/3/2019 |
Vulnerabilities in the Medicare Hospice Program Affect Quality Care and Program Integrity: An OIG Portfolio |
OEI-02-16-00570 |
7/30/2018 |
Hospices Should Improve Their Election Statements and Certifications of Terminal Illness |
OEI-02-00492 |
9/15/2016 |
Hospices Inappropriately Billed Medicare Over $250 Million for General Inpatient Care |
OEI-02-10-00491 |
3/30/2016 |
If you have a hospice program, these are important reports to review when conducting a risk assessment.