1.Summarize the hospice vulnerabilities identified by regulators and accreditors in the FiINDINGS section (page 7-15) of the U.S Department of Health & Human Services-Office of Inspector General r

1.Summarize the hospice vulnerabilities identified by regulators and accreditors in the FiINDINGS section (page 7-15) of the U.S Department of Health & Human Services-Office of Inspector General r
Hospice Care Inventory Management: 5 Top Challenges Posted: 4/11/17 8:00 AM    Author: Concordance Healthcare Solutions    Hospice providers deliver crucial services and care for patients and their families during the last stages of life and typically offer some form of home-based care where ever that home may be, such as: the patient’s residence a skilled nursing facility a rehabilitation center long term care facility Because hospice providers operate on very limited budgets, they need to exercise prudent control over expenses. Key to controlling costs is exercising careful inventory management. Here are five top hospice care inventory management challenges. 1. Developing Protocols and Treatment Programs Because of reimbursement challenges, great attention needs to be taken when developing care plans for patients. It’s essential that hospice providers work with healthcare suppliers to establish appropriate products for best patient care outcomes while practicing the customized treatment protocols. Staff training is an important aspect, and the healthcare disposable supplier should be able to offer assistance in this regard. 2. Cost Containment A crucial aspect of cost containment for hospice care is establishing the cost of each patient per day. One way to do this is to determine the actual cost per patient per day and to use a tracking program to monitor expenditures. It’s a good idea to work with your medical disposable supplier to work out ways to meet the budgeted patient per day cost while continuing to meet your patients’ requirements of care. 3. Mobile Ordering Needs Patient requirements are not always predictable. There’s a need to order additional supplies with minimal inconvenience. For fast and efficient service, ordering systems should be online and delivery systems should be such that timely delivery services are available. Additionally, it should be possible for supplies to be delivered direct to the patient’s home. A mobile-based ordering system means that orders can be placed immediately with supplies and costs tracked to each individual patient. 4. Inventory Control Systems The challenge of managing hospice care inventory can be eased through the use of inventory management tools linked to a database that tracks orders, deliveries and usage. Reporting tools should provide total usage figures, including items that are delivered direct to patient’s homes. The system should manage maximum and minimum stock levels and trigger order notifications when reorder points are reached. 5. Accessing Utilization Reports Hospice providers should have the ability to access utilization reports online. These should be customized to the needs of the hospice and available when required. Regular weekly and monthly reports should be automatically prepared. The administrator must be able to track costs per patient day, inventory costs, inventory usage and monitor overall spending by product and product category. By being compliant, you can take the sting out of unexpected variances. The Solution Concordance Healthcare Solutions, formed by the merger of Kreisers, MMS and Seneca, offers flexible, personalized, patient-friendly service as well as a suite of software products that simplify inventory management and patient care. These include our: Cost Per Patient Day tracking program Front Step patient supply delivery program Mobile ordering program Inventory and asset management, reporting and educational programs BeCompliant budgeting and tracking program
1.Summarize the hospice vulnerabilities identified by regulators and accreditors in the FiINDINGS section (page 7-15) of the U.S Department of Health & Human Services-Office of Inspector General r
NHPCO Responds to New OIG Reports on Hospice Care For Immediate Release:July 9, 2019 NHPCO welcomes the opportunity to shed a light on high quality providers as well as those that fall short in providing appropriate care. NHPCO will continue to partner with government agencies to strengthen and make more transparent the tools and data needed to empower consumers when they are choosing a quality hospice program. NHPCO will also continue to provide tools and resources to help our members to meet and exceed quality benchmarks. (Alexandria, Va) – This morning, the Office of the Inspector General released two new reports following its investigation into hospice care in the U.S.  To briefly summarize, the OIG found that 20 percent of hospices have deficiencies that put patients at risk and the OIG is suggesting that among its recommendations that deficiency data be shared more broadly to help improve quality of care. The NHPCO health policy team is reviewing the recommendations in the OIG reports and will issue a Regulatory Alert to the membership later today. News stories prompted by the OIG reports have been carried by The Washington Post, NBC News, and NPR. The journalists writing some of these news stories have shared selected patient stories based on their own investigation. These patient stories are difficult to read and reflect badly on hospice.  It is likely that other media outlets will carry these articles or generate additional news coverage on this topic. Many of the issues brought up in the new reports have been discussed in previous OIG documents going back to 2005. NHPCO has addressed these issues in the past through resources that include: Regulatory tools and alerts, quality resources, NHPCO’s Compliance Certificate Program, our updated Standards of Practice for Hospice Programs, throughout our webinar offerings, at our conferences, in our podcast series, in staff presentations to the field, and in work done by our board committees. NHPCO President and CEO Edo Banach would like to share some specific points with the field. NHPCO has been and continues to be a champion for accountability and transparency within the hospice community and we have long supported additional oversight of the hospice program, including survey frequency now at every 36 months, appropriate data collection, compliance and quality resources, and availability of education and professional development offerings to the field. Any hospice provider who fails to be fully compliant with all regulations and standards of practice and is unable or unwilling to provide the highest level of quality care should not be in the business of caring for the dying and their loved ones. The bottom line is that all hospices must ensure that every single patient receives care within all regulatory and statutory limits, that quality is never a question, and patient and family safety is never compromised. Hospices in the U.S. care for nearly 1.5 million Medicare beneficiaries and their family caregivers every year (see NHPCO Facts and Figures Report). The OIG has released information that should serve to assist the Centers for Medicare and Medicaid Services in its efforts to provide appropriate oversight of the hospice provider community and NHPCO looks forward to working collaboratively on such efforts. Extreme patient stories highlighted by the media that are not representative of the care most Americans receive can do more to frighten the public than inform them about the benefits of hospice care. NHPCO continues to stress that outliers in the field do not adequately reflect the vast majority of hospice care provision in the U.S. NHPCO believes that incidents of deliberate fraud and abuse in the hospice field, though isolated, are indefensible. However, it is necessary to understand that rare incidents of deliberate fraud and abuse should be viewed separately from unintentional documentation or mathematical errors in an extraordinarily burdensome and complicated regulatory environment. NHPCO looks forward to working with the Administration and Congress to simplify and streamline the hospice benefit and compliance process and to ease governmental red tape in order to encourage honest and law-abiding hospice providers while protecting the public from unacceptable intentional abuse. This includes better use of hospice data that CMS already obtains, educating CMS auditors, and to focus government efforts on abhorrent providers and spare compliant programs from needless and duplicative investigation. As with previous reports from the Office of the Inspector General, NHPCO recognizes the value of some of the OIG recommendations and we welcome measures that will help hospices deliver patient- and family-centered care that meets the highest quality standards. In media interviews, the OIG has clearly stated that they do not want to scare hospice patients and families away from hospice. Their focus is on quality of care and safety of patients and family caregivers, we share that with the OIG. Finally, it should be understood that hospices have a sacred obligation to serve patients and family caregivers throughout the end of life journey. As the hospice care community – like the rest of America’s health care system – continues to evolve to meet patient and family needs, it is critical that government regulations also adapt and modernize to meet the needs of those served by this unique care model.
1.Summarize the hospice vulnerabilities identified by regulators and accreditors in the FiINDINGS section (page 7-15) of the U.S Department of Health & Human Services-Office of Inspector General r
Hospice Industry Seeks Solutions to Issues in OIG Reports Debate continues about how the hospice industry, as well as regulators, should respond to the reports on hospice care issued in July by the U.S. Department of Health and Human Services Office of the Inspector General (OIG) that included recommendations to the U.S. Centers for Medicare & Medicaid Services (CMS) on changing their processes for evaluating compliance. The first OIG report indicated that about 20% of hospices surveyed by regulators or accreditors between 2012 and 2016 had a condition-level deficiency that posed a serious safety risk. A second report discussed 12 examples of those deficiencies in-depth. OIG examined state agency and accreditor survey findings as well as complaint data from 2012 through 2016. Regulators and accreditors surveyed nearly all hospice providers in the nation during those years. “These cases reveal vulnerabilities in CMS’s efforts to prevent and address harm that have implications for the wider hospice population,” OIG reported. “These vulnerabilities include insufficient reporting requirements for hospices, limited reporting requirements for surveyors, and barriers that beneficiaries and caregivers face in making complaints. Also, these hospices did not face serious consequences for the harm described in this report.” Though the OIG reports did identify some egregious examples of safety violations in hospices, the severity of regulatory deficiencies in general varies widely, ranging from instances that pose an immediate threat to a patient’s life and safety to relatively low-risk considerations such as clerical errors in patient documentation or a hand hygiene dispenser protruding an extra inch into the hallway of an inpatient facility. “Like a lot of things in life, it’s important to understand the context beneath [the reports]. There are some observations inside of it that will allow the industry and trade associations to begin a dialogue,” Nick Westfall, CEO of VITAS Healthcare, a subsidiary of Chemed Corp. (NYSE: CHE), said at the Home Health Care News Summit conference in September. “We can all agree that quality and transparency is absolutely a positive thing, but understanding the mechanics of it is an important component. The biggest fear is that when you start producing some of those reports without context for it, it may dissuade the exact thing that the country is trying to do and that ironically the government is trying to do, which is figure out how we get more people in to hospice and into hospice earlier.”   When it comes to concerns about hospice billing practices, the waters become even more murky. Documentation errors and omissions, live discharges and lengths of stay beyond six months are three red flags that could cause regulators to come knocking at a hospice’s door. However, though instances of fraud do exist, issues related to length of stay or live discharges often result from the ways the hospice patient population has changed since the Medicare Hospice Benefit was established in 1983.  The benefit, with its requirement of a six-month terminal prognosis, was originally designed to serve cancer patients, who have a more predictable disease trajectory than the patients with dementia and cardiac conditions that hospices care for today. Patients with these conditions are the most likely to see lengths of stay that exceed six months. “Scrutiny over lengths of stay are a product of the six-month requirement. Whether care is related or unrelated [to a patient’s terminal prognosis] or whether care is too long or too short is a product of the fact that hospice is a six-month prognosis benefit, and that patients can’t get concurrent care,” Edo Banach, president and CEO of the National Hospice & Palliative Care Organization said. “I think that should be changed, which would free providers and those who oversee them to actually look at the quality of care being provided. They are looking at the wrong thing.” The National Association for Home Care & Hospice (NAHC) recently made recommendations to CMS and other stakeholders to address the issues described in the OIG reports, including requiring CMS to publish a list of top deficiencies annually with a plan of action for addressing them. NAHC recommended increasing the frequency of surveys for hospices that have a history of serious deficiencies, including unannounced spot checks, making state agency and accreditation organization reports publicly available, and additional action to improve CMS’ process for capturing and responding to patient complaints and to strengthen the effectiveness of the survey process. The organization called for CMS to evaluate the consistency of state agency surveyor and accreditation organization surveyor actions that pertain to Medicare Conditions of Participation, as well as CMS regional office interpretations and applications. They also advocated or annual audits to ensue survey accuracy. “The OIG’s findings have made a valuable contribution to the knowledge base surrounding hospice quality of care. These include insights into the need for better education regarding commonly cited areas of deficiency as well as improved focus and appropriate corrective action toward providers that perform poorly as evidenced by a history of serious deficiencies and/or substantiated complaints,” NAHC indicated in a statement. “The OIG reports have also fostered discussion within the hospice industry around the need to eliminate inconsistencies in the survey process and flawed policy interpretations that create confusion.”
1.Summarize the hospice vulnerabilities identified by regulators and accreditors in the FiINDINGS section (page 7-15) of the U.S Department of Health & Human Services-Office of Inspector General r
Safeguards Must Be Strengthened To Protect Medicare Hospice Beneficiaries From Harm 07-03-2019 | Report (OEI-02-17-00021) | Complete Report WHY WE DID THIS STUDY Related Content 2019: Vulnerabilities in Hospice Care This report describes specific instances of harm to hospice beneficiaries and identifies vulnerabilities in CMS’s efforts to prevent and address harm. In past work, the Office of Inspector General (OIG) raised a number of concerns about the care provided to Medicare beneficiaries. As part of a recent portfolio, OIG found that hospices did not always provide needed services to beneficiaries and sometimes provided poor quality care. Hospice care can provide great comfort to beneficiaries, their families, and caregivers at the end of a beneficiary’s life. Medicare hospice beneficiaries have the right to be free from abuse, neglect, and other harm. When hospices cause harm or fail to take action when harm is caused by others, beneficiaries are deprived of these basic rights. This report is the second in a two-part series addressing hospice quality of care. The companion report identifies risks posed to Medicare beneficiaries from hospice deficiencies. HOW WE DID THIS STUDY We based this report primarily on 12 cases of beneficiary harm from a review of the survey reports for a purposive sample of 50 serious deficiencies in 2016. We reviewed the survey reports and the associated plans of correction to describe the 12 cases of harm and to gain an understanding of CMS’s efforts to prevent and address beneficiary harm. We purposively selected these 12 cases for review because of the severity of harm to the beneficiary. These cases do not represent the majority of hospice beneficiaries or hospice providers. They also do not reflect the prevalence of harm to hospice beneficiaries. WHAT WE FOUND Some instances of harm resulted from hospices providing poor care to beneficiaries and some resulted from abuse by caregivers or others and the hospice failing to take action. These cases reveal vulnerabilities in CMS’s efforts to prevent and address harm. These vulnerabilities include insufficient reporting requirements for hospices, limited reporting requirements for surveyors, and barriers that beneficiaries and caregivers face in making complaints. Also, these hospices did not face serious consequences for the harm described in this report. Specifically, surveyors did not always cite immediate jeopardy in cases of significant beneficiary harm and hospices’ plans of correction are not designed to address underlying issues. In addition, CMS cannot impose penalties, other than termination, to hold hospices accountable for harming beneficiaries. WHAT WE RECOMMEND These cases reveal vulnerabilities in beneficiary protections that CMS must address. The findings of this report provide further support for an existing OIG recommendation that CMS should seek statutory authority to establish additional, intermediate remedies for poor hospice performance. To effectively protect beneficiaries from harm, CMS must have enforcement tools. In addition, we make several new recommendations to strengthen safeguards to protect Medicare hospice beneficiaries from harm. CMS should (1) strengthen requirements for hospices to report abuse, neglect, and other harm; (2) ensure that hospices are educating their staff to recognize signs of abuse, neglect, and other harm; (3) strengthen guidance for surveyors to report crimes to local law enforcement; (4) monitor surveyors’ use of immediate jeopardy; and (5) improve and make user-friendly the process for beneficiaries and caregivers to make complaints. CMS concurred with the first four of these recommendations and partially concurred with the fifth. Return to top
1.Summarize the hospice vulnerabilities identified by regulators and accreditors in the FiINDINGS section (page 7-15) of the U.S Department of Health & Human Services-Office of Inspector General r
Hospice Quality Reporting Program What is the HQRP? The Hospice Quality Reporting Program (HQRP) was established under section 1814(i)(5) of the Social Security Act. The HQRP includes data submitted by hospices through the Hospice Item Set (HIS) data collection tool, data from Medicare hospice claims, and an experience of care survey, the Hospice Consumer Assessment of Healthcare Providers and Systems (CAHPS®) Survey. All Medicare-certified hospice providers must comply with these reporting requirements. The HQRP is currently “pay-for-reporting,” meaning it is the timely submission and acceptance of complete data that determines compliance with HQRP requirements. Performance level is not a consideration when determining market basket updates (referred to as Annual Payment Updates (APU)). Reporting compliance is determined by successfully fulfilling both the individual requirements of HIS and CAHPS®, and the submission of administrative data (Medicare claims). Penalties for Failure to Report Since 2014, failure for hospices to comply with quality data reporting requirements results in a percentage-point reduction to the Annual Payment Updates (APU). Effective with the 2022 Final Rule, beginning in 2024 penalty is increased from 2% to 4% for hospices who do not comply with the HQRP. Public Availability of Reported Data Care Compare on Medicare.gov is the official CMS website for publicly reporting quality measures for care provided by hospice and other health care providers. This site, which replaced the original Hospice Compare in 2020, was created to help consumers compare hospice providers’ performance and assist consumers in making decisions that are right for them. Consumers can search and download the publicly reported data displayed on Care Compare in the Provider Data Catalog on CMS.gov.