Hospice audits can have profound financial implications, particularly when the auditors use statistical extrapolation to identify an overpayment amount. The use of extrapolation runs across auditor types, including UPICs and...more
Hospices that have gone through audits are familiar with certain recurring reasons why auditors deny claims. Two common reasons are the lack of support for a six-month prognosis and the insufficiency of the physician...more
Hospices that have been audited have to decide how to address any alleged overpayment identified by the auditor, whether through a voluntary repayment, recoupment, or applying for an extended repayment schedule. CMS recently...more
UPIC activity is picking up, and the UPICs are reviving some old tactics. In this episode, Husch Blackwell’s Meg Pekarske and Bryan Nowicki continue the discussion on these trends which include extrapolation, Medicaid nursing...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
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
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
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
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
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
In today’s episode, Husch Blackwell’s Meg Pekarske talks with team members Bryan Nowicki and Erin Burns about two recent developments in the hospice audit arena. First, the Centers for Medicare & Medicaid Services (CMS)...more
In this episode, Husch Blackwell’s Meg Pekarske and Bryan Nowicki discuss the new wave of CMS Center for Program Integrity (CPI) audits that have been issued during the past couple weeks. These CPI audits remain focused on...more
Today's Episode: Spring Audit Bloom—Medicaid UPICs and MAC ADRs
Today, Husch Blackwell's Meg Pekarske is joined by colleagues Bryan Nowicki and Erin Burns to discuss the recent flurry of audit activity, specifically the...more
Hospice Audits Series
Audits are a fact of life for hospices—it’s not a matter of “if” a hospice will be audited, but “when.” The alphabet soup of audits has expanded, from UPICs to SMRCs, CPIs, TPEs and more. With the...more
The Trump Administration has shown an interest in regulatory reform with the goal of reducing the burden on regulated parties such as hospices. This has recently come to the forefront as part of the administration’s efforts...more
COVID-19 threw a wrench into certain hospice audit activity, but the machine rumbles on. In today’s podcast episode, Husch Blackwell's Meg Pekarske, Erin Burns and Bryan Nowicki discuss the current state of hospice audits,...more
In this episode, the hospice team shares insights on how to manage and succeed in responding to additional documentation requests (“ADR”) stemming from Targeted Probe and Educate (“TPEs”) projects. We discuss the unique...more