Tim Mullaney’s Post

About 14 years ago I took part in a meeting sponsored by Northwell health system and IHI that brought a dozen or so palliative care luminaries together to help the system think about their future clinical programs. I certainly wasn’t a pall care luminary but was invited because I had cared for one of the organizers in-laws when I was with the Mount Sinai visiting doctors program. When it came time for each participant to share their thoughts, I talked about how the easiest way to scale community based palliative care was through hospice providers. Hospice was already being provided in nearly every community across the country. At the time I was leading efforts to create a Supportive care benefit with the blues plan where I was living in Hawaii. This successful benefit is still provided through the hospice agencies across the state and pays for a concurrent model of care that some patients need. The Medicare Care Choices model tried something similar but paid less than a tenth hospice rates to care for patients who are oftentimes more complex and resource intensive. These patients still have multiple physicians who need to be in the loop and may be having continued chemotherapy or other treatments with untoward side effects that hospice nurses may be less family with. CMS has not found the right reimbursement for palliative care. The programs that have scaled community based palliative care are hospice providers (and with growth in MA, a few VBC providers like Aspire). These programs are essentially loss leaders that can expose hospice to regulatory scrutiny. Wouldn’t it make more sense to transparently acknowledge the huge need for palliative care and encourage hospice agencies to provide high quality services through FFS? They could even attach some quality metrics to official palliative care programs and report on investments into these programs. This might provide a race to the top rather than hugely variable “palliative care” programs often cloaked in a marketing budget for hospice. It took too long to measure quality in hospice, providing incentives for high quality in palliative care would benefit patients and caregivers tremendously. #palliativecare #healthcarequality #hospice

The data could give UPIC auditors clues as to potential malfeasance. However, the data extrapolation methodology is flawed and poses risks for quality hospice providers. #hospice #UPIC

Even the best hospice providers can get caught in a UPIC audit 📝, leading to long ⏳ and costly 💸 processes to untangle. Navigating the red tape can be tough, even when doing everything right. #HospiceCare #HealthcareCompliance #UPICAudit

If you or your loved one has Medicare, this article in Forbes explains the hospice care benefit in easy-to-understand terms. The author writes, "Many studies have shown that earlier end-of-life care can have a positive impact: reduced administration of unnecessary medications, fewer hospital admissions and less depression in survivors. As a homecare nurse, I witnessed the value of hospice care. Yet, in too many cases, it was a last-minute decision and neither the patient nor the family reaped the full benefit." What's been your experience with hospice care and Medicare? Read the article here: https://lnkd.in/dgR6ZpMm #hospicecare #hospice #medicare #medicarehospicebenefit

As a hospice CEO, I am ultimately responsible for ensuring that everything we do in our agency is above board - and legally and morally upright. Hospices face enormous scrutiny from CMS - and like it or not we need to follow the regulations or face the consequences. There are 4 levels of care that we all provide and one of the trickier ones is referred to as General Inpatient or GIP. In a nutshell, it's reimbursed at a higher level than routine home care and it requires scrupulous documentation to prove that the patient has a symptom that cannot be managed at home. You have to show what you've done to try and alleviate that symptom ( think bleeding, seizures, intractable pain) and why you need a higher level of care to manage the patient. GIP care cannot be done in a patient's home - it must be done in a facility that is certified to provide this level of care. Our hospice has very few GIP patients because we successfully manage symptoms through the diligence of our RNs, NPs, and Medical Directors. Recently, we received a patient from another hospice who was receiving GIP-level care for TEN DAYS. Most unusual. We could not find accurate documentation that supported this level of care - and ultimately we accepted the transfer for routine home care at the request of the family. The patient passed away peacefully in our care. This is the kind of behavior that gives hospices a black eye, and I only wish that all hospices would play by the rules. Higher reimbursement pays the bills - but sleeping well at night is the best reward one could hope for. Do the right thing and the rest will follow.

St Francis Hospice welcomes the first National End of Life Survey report (http://yourexperience.ie), especially its positive feedback about people’s experience of hospice care, including: “Participants whose relative or friend died in a hospice were more likely to rate their end-of-life care as ‘good’ or ‘very good’ (98%), when compared with a nursing home or residential care facility (92%), hospital (84%) or those who died at home (89%).” “In addition, participants were most likely to say they always felt welcome to visit their relative or friend in a hospice at any time (95%) in the last three months, compared with a nursing home (81%) or a hospital (58%).” “99% of participants whose relative or friend died at home said that they had died ‘in the right place’, compared with 94% for hospices, 89% for nursing homes and 75% for hospitals.” The learnings from this report enable us to adapt and improve our services to meet the changing palliative care needs of our community. HIQA - Health Information and Quality Authority Health Service Executive Irish Hospice Foundation Department of Health - Ireland Simon Harris Stephen Donnelly Maurice Dillon All Ireland Institute of Hospice and Palliative Care

According to HHS Office of Inspector General “Hospice care is for terminally ill patients who decide to forgo curative treatment and instead receive palliative care. To be eligible, a patient must be certified as having a terminal illness with a life expectancy of six months or less if the illness runs its normal course. Hospice care generally includes nursing and aide services, drugs, and supplies. It may be provided in a variety of settings, such as the patient's home, a nursing facility, or an assisted living facility. About 1.7 million Medicare beneficiaries receive hospice care each year, and Medicare pays about $23 billion annually for this care.” In the U.S., about 75% of the 6,000 hospice providers are for-profit, charging an average daily rate of $218.33 for the first 60 days and $172 thereafter. This model may incentivize enrolling as many patients as possible, leading to potential fraud, mismanagement, and abuse. A government report estimates improper billing in hospice care costs Medicare hundreds of millions annually. To combat this, rigorous oversight and transparency are crucial. Regular audits, stricter compliance checks, and active involvement from patient advocates and POAs can help identify and deter unethical practices. Highlighting reputable providers and reporting fraudulent ones will promote accountability and protect patients while acknowledging that many hospice agencies deliver high-quality care. https://lnkd.in/gxPx79Kx

An excellent report, well worth reading.

Relying on one primary referral source is too risky for hospices, according to Transcend CEO Stephanie Johnston. In an article by Hospice News on The Benefits of Diversifying a Hospice’s Referral Mix, Johnston further said: “We saw this amplified during COVID organizations that were heavily referral or heavily dependent on one type of referral. You’d be thinking about managing risk across multiple. And that’s exactly what hospice and home-based care providers need to do — think about a referral portfolio that they’re managing. That should include relationships with physicians, hospitals and SNFs.” Read the full article here: https://rpb.li/FuJRvn A lot of hospice referrals still come from hospitals, but don’t put all your eggs in one basket. Build relationships with multiple referral sources, including doctors, skilled nursing facilities (SNFs) or nursing homes, and patients & families. Patients and their families can also be valuable referral sources. By marketing directly to consumers, hospices can encourage earlier engagement with hospice care.

🚨 Important Reminders for Hospice Physicians! 🚨 Starting June 3, 2024, new Medicare regulations will take effect, requiring all certifying physicians to be enrolled in or have opted out of Medicare for hospice services to be reimbursed. This change is part of CMS's strategy to enhance hospice care quality and prevent fraud. 🔍 What You Need to Know: • Enrollment Requirement: Certifying physicians must be enrolled in Medicare or have submitted an opt-out affidavit. • Claims Denial: Claims will be denied if the certifying physician is not listed in the Provider Enrollment Chain and Ownership System (PECOS). • Enrollment Options: o CMS-855I: For those who plan to bill Medicare, certify services, or refer patients. Access CMS-855I o CMS-855O: For those who only order or certify services without billing Medicare. Access CMS-855O o Opt-Out Affidavit: For those choosing to opt out of Medicare but still want to certify services. Access Opt-Out Affidavit 🔗 Check Your Enrollment Status: • Ensure your enrollment status is active and compliant with the new rules by checking with your Medicare Administrative Contractor (MAC). Contact Your MAC • Verify your eligibility using the Provider Opt-Out Affidavits Lookup Tool. Use the Lookup Tool ⚠️ Action Required: • Hospice Organizations: Ensure your certifying physicians are compliant to avoid claim denials. • Physicians: Complete the necessary enrollment forms and verify your status before June 3, 2024. Let's work together to maintain the highest standards of hospice care and compliance. Share this post to spread the word and help ensure a smooth transition to the new regulations! Resources: CMS-855I Form: https://lnkd.in/euHa846V CMS-855O Form: https://lnkd.in/eWx-HfDr Opt-Out Affidavit: https://lnkd.in/eSsPh5v2 Contact Your MAC: https://lnkd.in/excTHXTg Provider Opt-Out Affidavits Lookup Tool: https://lnkd.in/exG4zYJ3 Change Request 13342: https://lnkd.in/evf73beP Medicare Provider Enrollment: https://lnkd.in/eAxpbiCh #HospiceCare #Medicare #HealthcareCompliance #Physicians #Hospice #CMS #RegulationsUpdate