LeadingAge, along with the three other national hospice associations (the National Association for Home Care and Hospice, the National Hospice and Palliative Care Organization, and the National Partnership for Healthcare Innovation), are partnering to collect information on various audits of hospice claims to share with the Centers for Medicare & Medicaid Services (CMS). Earlier this year, the associations sent a letter to CMS outlining our concerns which can be found here. In a follow up meeting with CMS, there was a mutual desire to focus on correcting issues related to the audits.
LeadingAge is asking members to help to collect examples of these audit issues – with no protected health information – particularly of technical denials. Technical denials are those where the review entity denies all or a portion of payment due to a hospice not meeting the technical requirements of the certification of terminal illness including the face-to-face and/or the Medicare hospice election statement, e.g., attestation requirement or certifying physician signature in the wrong place on the certification of terminal illness, Medicare hospice election statement not including specific terms/statements such as “palliative rather than curative nature” or the local Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO) telephone number not present on the election statement.
While they are primarily looking for technical denial examples currently, LeadingAge also welcomes examples of claim denials more substantive in nature. They will use this initial survey response to discuss common issues and develop solutions with CMS, but they will continue to be interested in hearing about hospice audit burdens and challenges from their members on an ongoing basis. You can direct those specific issues to Katy and Mollie. LeadingAge is keeping all responses confidential – no provider information will be shared. They are asking members to complete the following survey by October 31, 2023.
