Meticulous Documentation is the Best Defense in Hospice HIS Audit Appeals

November 10, 2022

Hospices need to be meticulous and vigilant with documentation to have the best outcomes when appealing payment cuts associated with Hospice Item Set (HIS) audits.

CMS developed HIS as a tool to gauge a patient’s overall care experience, requiring hospices to report HIS data for each patient or they could face a 2% payment cut.   Hospices can appeal those 2% reductions, and detailed documentation has shown to have the best chance to recouping those funds, according to Bryan Nowicki and Jacob Harris, hospice attorneys at the law firm Husch Blackwell.

“The hospices that have had success in HIS appeals have maintained meticulous ‘as-they-happen’ documentation of the circumstances relating to or resulting in non-compliance,” Harris and Nowicki told Hospice News in an email. “These ‘paper trails’ have provided critical information around which we have been able to build appeal arguments.”

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