Palliative care services are now more accessible to patients with serious and chronic illnesses in the United States. The Mayo Clinic defines palliative care as offering pain and symptom management and emotional and spiritual support when a patient faces a chronic, debilitating or life-threatening illness. Increasingly offered to patients of any age with a range of chronic illnesses such as cancer, multiple sclerosis and Parkinson’s disease, palliative care may be provided at the same time as curative medical regimens to help patients tolerate side effects of disease and treatment, and proceed with everyday life. According to a recent December 22, 2014 Wall Street Journal article, palliative care programs have increased three fold over the past decade. Many hospitals have specialized palliative care programs and 80% of hospitals with 250 beds or more provide such a program.
The provision of palliative care with or without curative treatment can lead increased patient and health care provider satisfaction, equal or better symptom control, less anxiety and depression, less caregiver distress, and potential cost savings. A patient’s quality of life can be enhanced with active and effective pain and symptom management. The need for aggressive pain and symptom management often lead patients to seek out a palliative care program to manage their symptoms during a chronic or terminal illness. Some patients also choose to utilize hospice care towards the end of their life journey after receiving services from a palliative care program. With the better availability of palliative care, those patients seeking pain relief and symptom control at any stage of their chronic or terminal illness care are able to find the services to address their needs including assisting the patient and the family to navigate the often complicated medical system.
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. Continue reading
The OIG recently made available its 2014 Work Plan. The Plan identifies OIG focus areas and priority projects for the coming year. This post provides a brief summary of many of the new OIG projects for fiscal year 2014 to assist providers in keeping abreast of the latest developments in health care fraud and abuse, compliance, reimbursement, and enforcement activities. Only a small part of the Plan is summarized here. For the entire document, please follow the link below. Continue reading
Posted in Acute Care, Community Based Care, Compliance Programs, Continuing Care, Durable Medical Equipment, Fraud and Abuse, Health Care, Health Care Providers, Hospice, Hospital, OIG, OIG Work Plans, Palliative Care
The Office of the Inspector General (“OIG”) issued a 2014-2018 strategic plan including outlining the visions, goals, and priorities of that office for the upcoming several years. The plan sets forth four goals: 1. Fight fraud, waste and abuse; 2. Promote quality, safety, and value; 3. Secure the future; and 4. Advance excellence and innovation. Each goals is identified with several priority areas that support the stated goal. The report can be found at the OIG’s website http://go.us.gov/WdbV
Posted in Acute Care, Ambulance, Ambulatory Surgery Centers, Anti-Kickback, Assisted Living, Clinical Laboratory, Clinics, Community Based Care, Compliance Programs, Continuing Care, Diagnostic Testing, Disability, Durable Medical Equipment, Fraud and Abuse, General, Health Care, Health Care Providers, Health Care Workers, Health Information Privacy, HIPAA, Home Health, Hospice, Hospital, Intermediate Care Facility, Long Term Care, Long Term Care Hospital, Medicaid, Medicare, Mental Health, Nursing Home, Occupational Therapy, OIG, OIG Reports, OIG Work Plans, Out-Patient Care, Palliative Care, Pharmacy, Physicial Therapy, Physician Assistants, Physicians, Post Acute Care, Primary Care, Regulatory Compliance, Rehabilitation, Rehabilitation Hospital, Residential Care, Senior Housing, Skilled Nursing Facility, Supplier, Transportation
Nursing facilities and skilled nursing facilities (collectively, “Nursing Homes”) will need to enter into written agreements, or revise existing agreements, with hospice providers, as well as implement new policies and procedures to meet the requirements of a final rule promulgated by the Centers for Medicare & Medicaid Services (“CMS”). The final rule, which can be found in the Federal Regulations at 42 CFR § 483.75(t), requires agreements between Nursing Home facilities and hospice providers to specifically address the roles and responsibilities of each entity and designate individuals responsible for oversight of related policies and procedures. Continue reading
Posted in Community Based Care, Final Rule, Health Care, Health Care Providers, Hospice, Long Term Care, Medicare, Nursing Facility, Nursing Home, Palliative Care, Post Acute Care, Regulation, Residential Care, Skilled Nursing Facility
Compliance program fatigue is nothing new. Over at least the last 15 years, health care organizations have jumped in head first, put together detailed manuals and taken the plunge. However, reimbursement cuts, quality initiatives, RACs, ZPICs, whistleblowers, physical plant renovations and simply significant industry challenges got in the way of sustaining an efficient and effective compliance effort. Health care organizations have also become desensitized to the barrage of compliance education, enforcement press releases, audits and reviews and other shock-value communications on the importance of regulatory compliance. In that vein, this very article may get lost in the shuffle, although, we hope it doesn’t.
An efficient and effective compliance effort with your organization is extremely important, if only as an insurance policy against government scrutiny. Additionally, the Patient Protection and Affordable Care Act of 2010, H.R. 3590 (“ACA”) includes requirements that CMS implement mandatory compliance program requirements for all providers and suppliers. In a distinct section of ACA, nursing home mandatory compliance programs were given a specific implementation timeline. Continue reading
Posted in Acute Care, Adult Home, Ambulatory Surgery Centers, Assisted Living, Clinical Laboratory, Clinics, Community Based Care, Compliance Programs, Continuing Care, Diagnostic Testing, Disability, Durable Medical Equipment, Fraud and Abuse, Group Home, Health Care, Health Care Providers, Health Information Privacy, Health Reform, Home Health, Hospice, Hospital, Intermediate Care Facility, Long Term Care, Long Term Care Hospital, Medicare, Mental Health, Nursing Facility, Nursing Home, Occupational Therapy, Out-Patient Care, Palliative Care, Pharmacy, Physicial Therapy, Physician Assistants, Physicians, Post Acute Care, Primary Care, Program Integrity, Regulatory Compliance, Rehabilitation, Rehabilitation Hospital, Residential Care, Senior Housing, Skilled Nursing Facility, Supplier
On October 2, 2012, The U.S. Department of Health and Human Services Office of the Inspector General (“OIG”) released its Work Plan for 2013. The OIG releases its work plan for each year in advance of the coming year. The work plan provides stakeholders in the health care industry with a broad overview of the OIG’s activities in the coming year as they relate to its enforcement priorities and issues it will review and evaluate during that fiscal year. This client alert is one in a series of alerts that will outline the OIG’s activities, as discussed in the 2013 Work Plan, for a specific industry sector – Hospice.
The OIG’s activities relating to Hospice for 2013 are focused on two issues that generally involved hospice –nursing home relationships. The following is a summary of each of the issues and what the OIG is focusing on. Continue reading
Posted in Compliance Programs, Fraud and Abuse, Health Care, Health Care Providers, Hospice, Medicare, OIG, OIG Work Plans, Palliative Care, Post Acute Care, Program Integrity