OIG 2014 Work Plan – Hospice

This article represents another installment of a series of articles that will outline the OIG’s activities, as discussed in the 2014 work plan, for a specific industry sector – hospice.

For 2014, the OIG’s activities relating to hospices are focused on the provision of hospice services in assisted living facilities, and quality of care.

Hospice in Assisted Living Facilities

Pursuant to the Affordable Care Act, CMS is required to reform the hospice payment system, collect data relevant to revising hospice payments, and develop quality measures for hospices. Hospice care is currently provided in a variety of settings, including private residences, skilled nursing facilities, and assisted living facilities. Among these various settings, residents in assisted living facilities have the longest average lengths of stay in hospice care. At the request of the Medicare Payment Advisory Commission, the OIG has been tasked with examining these long stays. In addition to examining length of stay, the OIG intends to examine levels of care provided, and common terminal illnesses among residents in assisted living facilities.

Hospice General Inpatient Care

In response to concerns regarding the potential misuse of hospice general inpatient care, the OIG intends to examine hospice general inpatient care claims. In performing such review, the OIG will examine the content of inpatient care election statements and relevant hospice beneficiaries’ medical records. The OIG also stated that it intends to report its findings in this regard during FY 2014.

Hospice providers should be aware of each of the above areas of inquiry in the OIG’s 2014 work plan, as OIG work plan priorities often result in additional enforcement actions, significant change in CMS policy, or both.

For more information regarding the OIG’s 2014 work plan, its priorities, Medicare and Medicaid integrity initiatives in general, or assistance with responding to an OIG inquiry relating to any issue, please contact Dan O’Brien at 216-363-4691, or dobrien@beneschlaw.com.

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