Thoughts on OIG Report on Hospice Inpatient Care

On Thursday March 31, 2016, the HHS Office of Inspector General issued a report on the use and misuse of hospice inpatient care in the Medicare Hospice Benefit. The study was undertaken as part of an ongoing effort at OIG to prevent inappropriate claims for hospice general inpatient care (GIP), including care being billed but not provided and beneficiaries receiving care they do not need.

As the oldest and largest leadership organization representing hospice and palliative care providers and professionals, NHPCO continues to welcome appropriate oversight of the field and works continually with its members to ensure their awareness of and compliance with all hospice related rules and regulations. NHPCO has also worked closely with Congress and CMS to promote policy changes that stem the abuses referenced in the report, and ensure a high quality hospice experience for consumers. 

Specifically, NHPCO recommends that hospices:

• Have a process and procedure for determining eligibility for the GIP level of care, that they document the reasons that GIP is appropriate for each patient, and evaluate continued eligibility for GIP EVERY DAY with documentation in the medical record that can be easily reviewed.
• Obtain a written physician order for a change in level of care. 
• Review use of GIP and the length of stay for each patient at the GIP level of care on a monthly basis, with documentation about the review in each patient’s medical record. 
• Review the development of plans of care for patients admitted to and continuing in the GIP level of care.
•  Develop a process for reviewing all medications, check and double check how medications are paid for and ensure that contract providers are billing appropriately.
• Review and update your processes at inpatient facilities to ensure daily evaluation of eligibility, detailed documentation to prove continued eligibility and accurate and complete care plans. 

NHPCO will continue to work with member organizations, policymakers, and other stakeholders to ensure that hospice claims are billed appropriately, and that beneficiaries experience high quality, compassionate care at the end-of-life.

See NHPCO's Regulatory Alert on the new OIG report for additional analysis and summary of the report.