Program integrity issues that have heated up in the hospice space during the past five years reached a boiling point in 2023. Hospice providers have seen an array of increased regulatory oversight in 2023. That momentum has been fueled by two main concerns among regulators — risks of patient safety and evidence of malfeasance in the space.
Hospice News sat down with providers, advocacy groups, legal experts and other stakeholders to uncover the most significant hospice.
Ramped up auditing activity
Hospices have seen an uptick in auditing activity during the past three years, a trend expected to gain speed heading into 2024.
Increased have been reported across multiple types of audits, including Targeted Probe and Educate (TPE) audits conducted by Medicare Administrative Contractors (MACS) and others involving Unified Program Integrity Contractors (UPIC), Supplemental Medical Review Contractors (SMRC) and Recovery Audit Contractors (RAC).
Audits around general inpatient care (GIP) stays have been among the most controversial and confusing points of contention in the hospice space.
Longer GIP hospice stays and high-cost issues are reasons the OIG this June launched a nationwide audit. Dubbed the “Audit of Selected, High-Risk Medicare Hospice General Inpatient Services,” the OIG will concentrate on Medicare claims for hospice enrollees transferred to GIP settings following an acute hospitalization. The audit is among a host of others in the health care space that the agency rolled out this month in its Work Plan initiatives. OIG anticipates the audit’s results to roll out in the fiscal year 2025.
The regulatory watchdog indicated that many hospice GIP claims are at “high-risk for inappropriate billing,” with roughly one-third of Medicare claims for these services billed in error on average each year.
The increased auditing activity also has hospices navigating a variety of different appeal processes that can place administrative burdens on billing and compliance staff. Additionally, the varied methodologies behind each individual audit has given rise to inconsistencies in the process. 
“When we’re talking about government audits, the focus areas the government is interested in [are] eligibility and levels of care, having the patient in the right care at the right time based on their acuity level. What we see most often in the payment denials are those audits for GIP stays. TPE probes also seem to be where the government is cherry picking claims that are often the most difficult to prognosticate and sometimes difficult to show on patient records. These audits tend to have higher error rates.”
– Carrie Uebel, senior vice president and chief ethics and compliance officer, Compassus
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