OIG Report: Frequency of Medicare Hospice Recertification Unimproved
September 10, 2013 10:56 AM
The Department of Health and Human Services Office of the Inspector General (OIG) sent a memorandum to the Centers for Medicare & Medicaid Services (CMS) dated August 29, 2013 expressing concern that state surveys of hospice compliance with the Medicare conditions of participation (CoPs) are not occurring as frequently as they should. The memorandum cited a 2007 OIG report that found that there was an average of nine years between federal hospice surveys and that 46 percent of surveyed hospices received citations for health care deficiencies - with the most frequently cited deficiencies related to care planning and quality issues.
CMS policy dictates the frequency of hospice surveys. Current policy is for hospices to be surveyed at least every seven years (sequestration moved this back from a previous standard of every six years). In the 2007 report, based on 2005 data, the OIG recommended that CMS seek statutory or regulatory timeframes for the frequency of hospice recertification surveys and suggested a timeframe of three years. This is also consistent with the timeframe adhered to by private accrediting organizations (AOs). CMS did not adopt the recommendation at that time due to the fact that additional resources were necessary. This 2013 memorandum finds that not much has changed in regards to hospice surveys since the 2007 report.
The frequency of hospice recertification surveys has not improved since 2005, with 17 percent of State-surveyed hospices not having been recertified within the lastsix years. In 2005, 14 percent of state-surveyed hospices had not been recertified within the previous six years. The OIG found the length of time between surveys averaged 8.4 years and ranged as high as 22 years for hospices in the 2013 study. It should be noted that the OIG’s study excluded complaint surveys and those hospices that have deemed status and were surveyed by one of the AOs.
Based on these results, the OIG reiterated its recommendation from 2007 that CMS set specific timeframes for the frequency of hospice recertification surveys by seeking legislation or promulgating regulations. The memorandum further stated:
“These findings illustrate that CMS’s use of fluctuating annual targets does not ensure timely recertification surveys of all hospices and raises concerns about whether CMS and contracted State survey agencies can adequately oversee hospice compliance with Medicare CoPs and the quality-of-care requirements for hospices. Our research also indicates that hospices are often out of compliance; the 2007 report found that almost half of hospices were cited with deficiencies when surveyed. Further, more recent OIG reports identified quality-of-care concerns regarding hospice care provided in nursing homes.”
The National Association for Home Care & Hospice (NAHC) and its affiliated Hospice Association of America have long supported an increase in the frequency of routine surveys so that each hospice is surveyed for compliance with the CoPs at least every three years.