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Hospice – Nursing Home Relationships – Compliance Reviews

Hospice Compliance Reviews – OIG Focus On Hospice Admissions

Hospice Admission Criteria ComplianceThe OIG has repeatedly expressed suspicion about hospice relationships with nursing homes and admission of “marginal” hospice patients who reside in nursing homes.  Hospices should routinely monitor their percentage of patients who reside in nursing homes and audit admission decisions relative to those patients.  This is an area of frequent review and hospices should assure that each nursing home/hospice patient meets admission criteria.

OIG also expressed concern over hospice marketing materials that could lead to inappropriate admissions.  Marketing materials should accurately describe the nature of hospice care and the criteria that must be met to receive hospice benefits.  Of particular importance is assuring that marketing materials clearly describe the requirement that the patient forgo any curative treatment in order to maintain eligibility for hospice benefits.

Misuse of hospice inpatient care is also prominent on the OIG’s radar.  Medical records of inpatients are vulnerable to review by the government to confirm the appropriateness of inpatient hospice benefits.  Hospices should add review of inpatient care admissions to their list of audit and review items if they have not already done so.

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John H. Fisher

Health Care Counsel
Ruder Ware, L.L.S.C.
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