NHPCO Responds to OIG Report

To:       NHPCO Membership
From:   Edo Banach, President and CEO

Date:   July 31, 2018

As many of you may be aware, the Office of the Inspector General has released a portfolio report, “Vulnerabilities in the Medicare Hospice Program Affect Quality Care and Program Integrity,” focusing on concerns with the Medicare hospice benefit. NPR’s Morning Edition and Kaiser Health News (which concludes with some important quotes I offered before the report was released) both did pieces on the report that I’m sure some of you have read or heard this morning.

Let me stress that many of the issues brought up in the new report have been discussed in previous OIG documents. NHPCO has addressed these issues in regulatory alerts and resources, on our Webinars, at our conferences, in staff presentations to the field, in our Regulatory Podcasts, and explored by our board committees. So, I hope the contents of the report do not come as a complete surprise and cause you to be too discouraged.

Let me offer some additional comments and context in response to this OIG report.

• NHPCO recognizes the value of some of the OIG recommendations and we welcome measures that will help hospices focus on value over volume and patients over paperwork.
• However, NHPCO continues to stress that outliers cited in the report do not adequately reflect the context of hospice care provision in the U.S.
• Importantly, CMS rejects over half of the OIG’s hospice recommendations, and we generally agree.

We believe that incidents of deliberate fraud and abuse in the hospice field, though rare and isolated, are indefensible. For this reason, NHPCO has been and continues to be a champion for accountability and transparency within the hospice community. And we look to our members to be our partners in this important work.

Furthermore, it is necessary to understand that rare incidents of deliberate fraud and abuse should be viewed separately from unintentional documentation or mathematical errors in an extraordinarily burdensome and complicated regulatory environment.

We look forward to working with the Administration to simplify and streamline the hospice benefit and compliance process and to ease the governmental red tape in order to encourage honest and law-abiding hospice providers while protecting the public from unacceptable intentional abuse. This includes better use of hospice data that CMS already obtains and to focus government efforts on truly abhorrent providers and spare compliant programs from needless and duplicative investigation.

NHPCO encourages the OIG and CMS to examine ways in which the current structure of the benefit can prevent patients and families from accessing medically necessary care and subject them instead to more costly and less beneficiary-friendly environments. Also important to examine is underutilization of hospice care. As reported in our annual Facts and Figures Report, 28 percent of beneficiaries received care for only seven days or less in 2016. Like intentional fraud, this is unacceptable.

Hospices have a sacred obligation to serve patients and family caregivers throughout the end of life journey. As the hospice care community – like the rest of America’s health care system – continues to evolve to meet patient and family needs, it is critical that government regulations also adapt and modernize to meet the needs of those served by this unique care model. Let us work with the OIG, CMS, and Congress to build on our 35 years of experience with the Medicare hospice benefit to seek solutions in caring for people facing serious and life-limiting illness.

Pediatric Focus at IDC 2018

NHPCO and the ChiPPS Leadership Advisory Council are excited to announce that there will be a pediatric preconference seminar at this year’s Interdisciplinary Conference in New Orleans, Louisiana! IDC will also include a pediatric concurrent session track.

The pediatric preconference seminar, Expert Interdisciplinary Care for the Developing Pediatric Team, will increase your competence and confidence in caring for pediatric patients of all ages and their families. Seasoned and accomplished faculty will lead you through case-based learning activities to increase your skills in providing expert interdisciplinary care, communicating effectively and facilitating decision-making, all while gathering clinical pearls to apply to your care of children and their families. From childhood development and its impact on symptom management, advance care planning, grief and loss to applicable regulatory requirements, the depth and breadth of this interactive workshop will educate, motivate and inspire you.

Learning Objectives:

·      Apply case-based learning activities to expert interdisciplinary care of children and their families

·      Improve communication and facilitation skills in working with pediatric families

·      Apply clinical pearls (creative medical, psychosocial, spiritual and bereavement approaches) to your care of children and their families

Participate in the pediatric preconference seminar on November 4, 2018; and stay for the main conference November 5-7, 2018 where there will be pediatric concurrent sessions throughout the three days. We look forward to learning and sharing with our pediatric hospice and palliative care providers!

“Come join us for an interactive day of learning and networking. It is a great opportunity to learn from and with others in the pediatric hospice and palliative care community. Every year, I am amazed by all the work my colleagues are doing every day to further the field of pediatric hospice and palliative care. The opportunity to share and learn from one another has been invaluable to me in my professional growth and development.”

– Holly O. Davis, MS, APRN

   Co-chair, ChiPPS Leadership Advisory Council

Visit the IDC 2018 web page for more information or to register online.

PCHETA Call to Action!

The Palliative Care and Hospice Education and Training Act (PCHETA) passed a procedural hurdle today and was reported out from the House Energy and Commerce Committee to the full House of Representatives for its consideration. 

This means it is on its way to being scheduled for a vote! We need you to Take Action Now to request a timely scheduling of the vote, and to ask your Representative to vote YES. 

Click here to be taken to our PCHETA Action Center, where you can make a phone call, send an email, and post social media messages urging the House to act quickly to schedule and pass PCHETA.

Thank you to the many, many advocates and organizations who have worked tirelessly for years to see this legislation through the process. We are so close, won't you take a few minutes to help us over the finish line?

Thank you for your dedicated advocacy on behalf of patients and families nationwide. We really can do amazing things when we all work together. Now, let's pass PCHETA.

Be the Cheetah on the Right

I recently had the pleasure to take a bucket-list trip to South Africa with my family. Ostensibly, I was there to attend a board meeting of the Worldwide Hospice Palliative Care Alliance in Durban. Of course, I had to take the opportunity to travel around this magnificent country. I was humbled by the massive disparities between rich and poor in Durban and simply awestruck by the wildlife at the Cape of Good Hope and the power of the Zambezi River and Victoria Falls.

However, no moment was as impactful as the one I captured in the photograph above. The guide explained how rare it is to see a cheetah, let alone to see four gathered in one place. But what was most amazing about this moment came from what you can’t see. To the left of the adolescent cheetahs sits an airstrip. Three of the cheetahs are transfixed by an airplane and activity on the runway—much like my own kids. The cheetah on the right has her siblings’ backs, both literally and figuratively. She is not letting herself get distracted and appears acutely aware of the hungry predators lurking in the distance off camera, including a pride of lions and a female leopard.

As I study the cheetahs today, I wonder if we are at a similar inflection point in our own world. Do we clearly see the threats and opportunities?  We tend not to focus enough on the actual threats that are lurking just beyond what is easy to see and feel, but that which surrounds us and divides us. Tax status, geography, medical specialty, discipline, political persuasion—these are the distractions that the cheetahs on the left obsess over. The cheetah on the right is looking a bit further out, worried about real threats and actively planning to turn future threats into opportunities.

As I reflect on this scene, I am struck by many of the insights that Michael Burcham shared with us during his plenary presentation at April’s Management and Leadership Conference. He addressed some of the disruptors that are affecting all health care providers– many of those involving technology. Based on his experience, he shared concerns that we as a field are missing important signals that are playing out in front of us right now. For those not able to attend the last MLC, Michael’s plenary presentation, TheFuture of Healthcare, is available to the membership free-of-charge on NHPCO’s E-OL , our online learning portal.

Additionally, Michael is serving on NHPCO’s Advisory Council – a new group of experts and thought-leaders that pulls from both within and outside of our professional community. So we will continue to benefit from his knowledge and experience.

I love this picture because of what it says about life—both personally and professionally. Love each other, don’t obsess over the immediate crisis, and look a bit further out to get some perspective. In this one moment, I feel a bit more clarity about our mission here. Let the ones whose aim is not rooted in person-centered, interdisciplinary care be the cheetah on the left. Through all of our differences and challenges let us be the cheetah on the right.

By Edo Banach, JD
President and CEO
National Hospice and Palliative Care Organization