December 16, 2009
Hospice Providers: OIG Alert
The HHS Office of Inspector General has recently released their findings in regards to hospice services. Please take note of these findings and work with your hospice agency to identify and correct deficiencies. By doing so you help assure that the care you expect is delivered and that documentation deficiencies that may allow for denial of claims and /or recoupment of funds has been addressed and corrected in compliance with CMS requirements.
- Thirty-three percent of claims did not meet
election requirements. For 4 percent of claims, there were no
election statements. For another 29 percent of claims, the election statements
did not meet one or more regulations. Most commonly, the statements did
not explain that hospice care was palliative rather than curative or that
the beneficiaries waived Medicare coverage of certain services related
to their terminal illnesses.
For another 9 percent of claims, the election statements contained misleading language about the beneficiaries' right to revoke the election of hospice care. - Sixty-three percent of claims did not meet plan of care requirements. For 1 percent of claims, the hospices did not establish plans of care for the beneficiaries. For another 62 percent of claims, the plans did not meet at least one Federal requirement. These plans of care were not established by an interdisciplinary group; they did not include necessary components, such as a detailed description of the scope and frequency of services; or they did not specify intervals for review, as required.
- For 31 percent of claims, hospices provided fewer services than outlined in beneficiaries' plans of care. For 31 percent of claims, the hospices did not provide the number of services outlined in the plans of care that they established. Most commonly, the hospices provided services to the beneficiaries but not as frequently as called for in the plans of care. In the most extreme cases, there was no documentation in the medical records of any visits for a particular service.
- Four percent of claims did not meet certification of terminal illness requirements. For 4 percent of claims, the certifications were missing or did not meet one or more Federal requirements. For these claims, the certifications did not specify that the individuals' prognoses were for life expectancies of 6 months or less if the terminal illness ran its normal course; they were not supported by clinical information and other documentation in the medical records; or they were not signed by physicians.
More information on the exact requirements may be found on the internet:
