Crossroads for Hospice

Hospices are under intense pressure from numerous federal rules and regulations.  Medicare reimbursement for Hospices is not keeping up with inflation. CMS is targeting hospices that have a high percentage of long length of stay patients.  Several of the Medicare Administrative Contractors (MACs) have initiated special audit steps to review hospice claims that have high length of stay to ensure they have the proper documentation and were good candidates for hospice when they were admitted.

Many hospices have been audited by Zone Program Integrity Contractors (ZPICs) and Recovery (RACs) for various claim issues. Always remember that ZPICs and RACs are bounty hunters.  They get paid for what they deny.  In my opinion auditors should not be paid bounties.  This creates a need to find problems whether they exist or not.  A very large percentage of these denials are overturned when they are taken through the appeal process.  Unfortunately many hospices do not have the funds or the expertise to complete the appeals process.

CMS in the proposed hospice rules and rates for 2014 have really hit the diagnosis issue hard.  They have removed adult failure to thrive and debility as primary hospice diagnosis, even though these were both in the top 5 hospice diagnosis last year.  There is no waiting period for this rule.  CMS stated that this was simply a clarification of existing rules.  They will allow adult failure to thrive and debility as secondary diagnosis.  CMS reported that most hospice claims had only one diagnosis.  They want hospices to include all secondary diagnosis related to the terminal condition.  This is a large change and will require intense staff training.

Hospices have to comply with the revised HIPAA rules.  Failure to comply can lead the excessive fines and penalties.  The Healthcare Reform Bill will eventually cost hospices cash and will require additional administration expense.  There are also fines for hospices that fail to comply.  Have you noticed all of the various fines and penalties?  This appears to be a new found revenue source for Medicare and other government programs.

Hospices are at a crossroads.  They must either learn to comply with the new rules and regulations or they will be forced out of business.  Successful hospices will know the rules, regulations, and will implement plans to ensure they are complying.

We are having an excellent seminar on September 18 to 20 that will discuss all of the above issues and much more.  It will be held at the Hilton Waikoloa Village on the Big Island of Hawaii.  The room block will be released on August 15.  Make your reservations prior to that date.