Hospices are increasingly looking to buy, consolidate, or merge to achieve administrative efficiencies and expand operations for growth. A common approach among nonprofit hospices is to combine through a member substitution....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
In this episode, Husch Blackwell’s Meg Pekarske and Jonathan Porter, a former federal prosecutor, discuss takeaways from the recent American Bar Association’s Annual National Institute on Health Care Fraud. Most importantly,...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
Earlier this spring, as part of its annual rulemaking process for hospices, the Centers for Medicare and Medicaid Services (CMS) issued several important regulatory proposals. In addition to the yearly update in hospice per...more
The HIPAA regulations require that covered entities enter into agreements with business associates who provide certain services for the covered entity involving the receipt, use, or disclosure of protected health information....more
The U.S. Department of Health and Human Services’ Office of Inspector General (OIG) reported in November 2022 that many providers are not complying with Medicare’s billing rules for advance care planning services. In large...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
While direct patient billing may be less common for hospice patients than for patients receiving hospital or other types of care, there are aspects of the No Surprises Act and its implementing regulations that are important...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
The hospice physician plays an enormously critical role in hospice operations, from certifying patients as terminally ill to being the hospice’s representative in the community. Just as the physician’s role is critical, so...more
The hospice certification of terminal illness is one of the documents most scrutinized by Medicare contractors, and it is of critical importance since an invalid certification can impact Medicare payment for the patient’s...more
Husch Blackwell’s Meg Pekarske is joined today by Mary Kay Tyler, Chief Quality and Compliance Officer of Hospice of the Western Reserve, who shares strategies for achieving the elusive goal of improved clinical...more
Hospices are increasingly looking to buy, consolidate or merge to achieve administrative efficiencies and expand growth opportunities. Transactions between hospices present unique regulatory challenges that shape corporate...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
The hospice election may be the single most important document for hospices since an invalid form can impact payment for a patient’s entire stay. Especially in light of a recent rise in Medicare claim denials related to the...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
Husch Blackwell’s Meg Pekarske is very excited to be joined by Jaysen Roa, President and CEO of Avow Hospice in Naples, Florida. Jaysen is a leader of action who is finding new ways to approach and solve the challenges facing...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