OIG 2014 Work Plan Includes New Work on Hospice in Assisted Living Facilities
February 3, 2014 04:41 PM
The Department of Health and Human Services (HHS) Office of the Inspector General (OIG) recently issued its Work Plan for fiscal year (FY) 2014, which summarizes new and ongoing reviews and activities that the OIG plans to pursue with respect to HHS programs and operations during the current fiscal year (FY) and beyond. Hospice has been an area of increased examination by the Centers for Medicare & Medicaid Services (CMS), the OIG, and others in recent years.
Of note in the OIG’s new Work Plan related to hospice is the continuing study of use of hospice General Inpatient (GIP) care as well as the announcement of a new line of inquiry related to use of hospice in assisted living facilities (ALFs).
Following are excerpts from the Work Plan:
Hospice in Assisted Living Facilities (new)
Policies and Practices
We will review the extent to which hospices serve Medicare beneficiaries who reside in ALFs. We will determine the length of stay, levels of care received, and common terminal illnesses of beneficiaries who receive hospice care in ALFs. Context—Pursuant to the Affordable Care Act, § 3132, CMS must reform the hospice payment system, collect data relevant to revising hospice payments, and develop quality measures for hospices. Our work is intended to provide HHS with information relevant to these requirements. Medicare covers hospice services for eligible beneficiaries under Medicare Part A (Social Security Act, § 1812(a)). Hospice care may be provided to individuals and their families in various settings, including the beneficiary’s place of residence, such as an ALF. ALF residents have the longest lengths of stay in hospice care. The Medicare Payment Advisory Commission has said that these long stays bear further monitoring and examination. (OEI; 02-14-00070; expected issue date: FY 2014; work in progress; Affordable Care Act)
Hospice General Inpatient Care
Quality of Care and Safety
We will review the use of hospice GIP care. We will assess the appropriateness of hospices’ general inpatient care claims and the content of election statements for hospice beneficiaries who receive general inpatient care. We will also review hospice medical records to address concerns that this level of hospice care is being misused. Context—Hospice care is palliative rather than curative. When a beneficiary elects hospice care, the hospice agency assumes the responsibility for medical care related to the beneficiary’s terminal illness and related conditions. Federal regulations address Medicare conditions of participation for hospices (42 CFR Part 418) Beneficiaries may revoke their election of hospice care and return to standard Medicare coverage at any time (42 CFR § 418.28). (OEI; 02-10-00491; 02-10-00492; expected issue date: FY 2014; work in progress).
The National Association for Home Care & Hospice (NAHC) and its affiliated Hospice Association of America (HAA) will monitor activity of the OIG and other entities relative to hospice care and continue to report on these in future editions of NAHC Report and Hospice Notes.