UPIC activity is picking up, and the UPICs are reviving some old tactics. In this episode, Husch Blackwell’s Meg Pekarske and Bryan Nowicki discuss these trends which include extrapolation, Medicaid nursing home room and...more
Recovery Audit Contractors (RACs) have played a relatively limited role in the hospice space, often overshadowed by UPICs, SMRCs, and Center for Program Integrity audits. In this episode, Husch Blackwell’s Meg Pekarske and...more
Hospice Targeted Probe and Educate reviews (TPEs) continue to be initiated all over the country. That means it’s time to check in with Husch Blackwell’s Hospice team on the latest developments. In this episode, Meg Pekarske...more
Five years ago, the U.S. Department of Health and Human Services Office of Inspector General (OIG) initiated audits of 13 hospices and published its findings in 13 separate reports. It appears that the OIG is at it again, as...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
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
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
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
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
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
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
COVID-19 remained a substantial obstacle to hospices’ efforts to comply with quality data reporting obligations in 2021. Those challenges resulted in a number of hospices receiving notices of a 2% Medicare payment reduction...more
For the last two-and-a-half years, hospices and other providers have been using billions in Provider Relief Fund (PRF) payments to prepare for, respond to and recover from the COVID-19 pandemic. The Office of Inspector...more
In this episode, we continue our discussion of home health enforcement trends, focusing on other audits currently troubling agencies. These include audits from Unified Program Integrity Contractors (UPIC), Supplemental...more
In a prior podcast, we alerted you to the Office of Inspector General’s (OIG) nationwide review of hospice beneficiary eligibility. The OIG has begun sending out requests for records to hospices across the country. In this...more
As many hospices continue to diversify into new business lines, staying abreast of enforcement trends outside of hospice is more important than ever. Home health in particular, is receiving significant government scrutiny. In...more
The core of most hospice audits has been, and continues to be, whether the medical record supports the patient’s hospice eligibility. In this episode, Husch Blackwell’s Meg Pekarske talks with Bryan Nowicki and Zaina Niles...more
The Centers for Medicare & Medicaid Services (CMS) has recently started mailing letters inviting physicians to one-on-one training sessions about the Medicare hospice benefit. In this episode, Husch Blackwell’s Meg Pekarske,...more
Unified Program Integrity Contractor (UPIC) audits are on the rise, and the UPICs are embracing the full array of enforcement tools at their disposal. In this episode, Husch Blackwell’s Meg Pekarske and Bryan Nowicki discuss...more
As audit activity escalates, hospices are getting increasingly familiar with the alphabet soup of audits and auditors, including OIG, UPIC, CMS, CPI, SMRC, MAC, TPE and more. Unfortunately, there are times when hospices are...more