Posted Saturday, June 5, 2021
Since March, the CMS Center for Program Integrity (CPI) has been issuing requests for records to hospice agencies throughout the country. Beware! These are not the usual ADR (Additional Document Request) requests from your MAC (Medicare Administrative Contractor) or SMRC (Supplemental Medical Review Contractor). Instead, these CPI audits are like UPIC (Unified Program Integrity) audits, and you must answer them promptly and carefully.
The CPI audits are targeting long length of stay hospice patients. The letters instruct hospice agencies to submit the entire medical record (not just related to a few certification periods or claim dates) as well as various other documents. The list of documents requested includes copies of physician licenses who were associated with the patient, the hospice physician’s contracts, as well as various other related documents. It is important to read the request letter carefully as it contains a lengthy list of requested documents and a due date usually within 30 days.
The requests have been issued to hospice agencies of various sizes and are not related to the results of their PEPPER reports. Agencies have reported concerns as their PEPPER reports demonstrate that their percentage of long length of stay patients is within the national average.
Due to the volume of documents that the hospice agency must produce, we have assessed that the risk of denial or partial denial is high. Should the audit documentation be denied, CMS will recoup money already paid to you and agencies will have to go through the appeals process.
The first CPI audit requests for hospices were dated in late March and another batch of letters were issued in late April. Check to find out if you have received a CPI audit request and be prepared to respond thoroughly and quickly. An unexpected audit request can stretch your already thin resources. Let Corridor’s team of experts assist you with your response. Corridor can help you gather and organize your documents, review the record for compliance and assist with the appeal process.
Call us today to find out more about how you can leverage our documentation experience to help your agency meet this regulatory challenge. Please contact Corridor at 1-866-263-3795.
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