The Centers for Medicare & Medicaid Services has issued another major change for hospice providers: a retooling of the survey process.
While not unexpected, the latest guidance, in part, requires more research and investigation by surveyors during the pre-survey process. The action represents yet another move by the federal government to intimidate and root out bad actors, who have been proliferating the space for some time.
“I do believe that what this change represents is a focus for CMS to, from all aspects, really elevate quality of care and ensure that there are only … [well]-intentioned providers out there,” Katie Wehri, director of home Health and hospice regulatory affairs for the National Association for Home Care & Hospice, told McKnight’s Home Care Daily Pulse this week.
One adjustment hospices are going to make with this new survey guidance is to revisit how they communicate with patients, families and other providers, such as nursing facilities, to ensure that beneficiaries know exactly what kind of care is being delivered.
“They’ll probably take a look at that a closer look at that today and say, you know, are we communicating in a way that ensures that the patient and family fully understand what hospice care is, and that they have significant or, maybe I should say, meaningful input into their plan of care and what services they’re receiving?” Wehri noted.
One of the overriding reasons behind this scrutiny by surveyors is the perceived overuse and misuse of hospice and other services, Wehri suggested. For respite care, for example, patients “may not know how many days of care they’re going to be receiving and that they don’t have to take all five days at one time if they don’t need it.”
There is more tough love coming. CMS will share additional information about the Special Focus Program — which would subject problem providers to enforcement remedies and more frequent surveys — in the proposed hospice rule due out this year. At some point, it also will release revisions to Chapter 10 of the Program Integrity Manual to reveal how it is training surveyors on implementing enforcement remedies. In 2021, CMS established civil monetary penalties for noncompliant hospice programs. Per-day penalties can range from $500 to $10,000, and per-instance penalties can range from $1,000 to $10,000.
Not exactly a fun time to be a hospice provider. But given how regulated the environment is becoming, at the end of this upheaval, (as Wehri suggested) the hospice providers left standing will be the only ones CMS, ultimately, wants.
Liza Berger is editor of McKnight’s Home Care. Email her at [email protected].