NAHC and Three Other Organizations Talk Hospice Program Integrity with CMS Administrator

Posted February 22, 2023

The National Association for Home Care & Hospice (NAHC) and three other organizations – Leading Age, the National Hospice and Palliative Care Organization (NHPCO), and the National Partnership for Healthcare and Hospice Innovation (NPHI) – met with Centers for Medicare and Medicaid Services’ (CMS) Administrator Chiquita Brooks-LaSure to share concerns and recommendations to address the rampant growth in the number of Medicare certified hospices in some states and how CMS can protect Medicare beneficiaries receiving hospice care.

The discussion with CMS also suggested that additional oversight is needed to address hospice program integrity concerns and to ensure that Medicare beneficiaries receive quality hospice care when it is needed at the end of life. Based on the discussion, it is clear that CMS is deeply engaged on this issue and committed to taking action.

Topics discussed in the meeting included:

  • The alarming recent growth of the number of Medicare certified hospices in California, Arizona, Nevada, and Texas, many of which are found at the same address or with the same administrator or other key staff and with a concern for possible fraudulent activity.
  • A discussion of some of the 34 recommendations made by the four national hospice organizations as they collaborated to share legislative and regulatory changes to strengthen hospice oversight and program integrity with CMS and key Congressional stakeholders.
  • Our strong support of a targeted, temporary moratorium on new Medicare certified hospices in counties with troubling trends in the growth of Medicare certified hospices.
  • Our recommendation that CMS develop a list of red flag criteria in the Medicare certification application process, which would trigger additional oversight by the accrediting organization or state survey agency before Medicare certification could be approved. Red flags should include concerns such as: co-location of multiple hospices at single address, a single hospice administrator overseeing multiple hospices, and a patient care manager or other hospice leadership staff serving multiple hospices.
  • Additional regulatory requirements, including additions to the Medicare Hospice Conditions of Participation, such as an education or experience requirement for a hospice administrator or patient care manager and more frequent surveys for new hospices, which would strengthen the ability of a newly certified hospice to be compliant and provide quality hospice care.

“We were very encouraged by the strong interest in this issue expressed by Administrator Brooks-LaSure, and the clear indication that CMS is already taking action to address some areas of concern in a targeted and meaningful way,” said NAHC President William A. Dombi. “We look forward to continued work with our colleagues at the national hospice associations and with policymakers to protect the integrity of the hospice benefit and preserve access to vital hospice services for vulnerable patients and their loved ones.”

NAHC, LeadingAge, NHPCO, and NPHI expressed our appreciation for Administrator Brooks-LaSure’s time and our collective commitment to working alongside lawmakers and regulatory bodies to ensure that Medicare beneficiaries get the end-of-life care they want and deserve.

The four national organizations will continue to collaborate, in addition to working with our respective memberships, to refine solutions; understand their implications for patients, families, and providers; and amplify our advocacy activity.

Source: NAHC

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