Hanson Bridgett LLP
March 10, 2015 - United States of America
OIG Report Scrutinizes Hospice Care Provided in Assisted Living Facilities
by Tomek Koszylko
In January, the Office of Inspector General of the U.S. Department of Health and Human Services (“OIG”) released a report reviewing hospice care provided to Medicare beneficiaries in assisted living facilities (“ALFs”) . The report finds that Medicare spending on hospice services in ALFs has surged in recent years, and that Medicare may be creating improper financial incentives for hospices to provide care to beneficiaries in ALFs. It recommends that the Centers for Medicare and Medicaid Services (“CMS”) examine certain billing trends and reform the hospice payment model to reduce the incentives that may be leading to overbilling by some hospices for care provided in ALFs.
The report finds the following:
Based on the above findings, the report recommends that CMS take the following actions:
While the report does not expressly accuse hospices of overbilling for ALF-based services, it does send a clear message that the OIG considers certain billing practices to be questionable. In response to the report, CMS has acknowledged that hospice reimbursement should be evaluated, but that further investigation will be necessary before it can implement many of the report’s recommendations. Nevertheless, hospices are well-advised to review their ALF-based practices now to reduce the risk of becoming a target for CMS audits later.
 Office of Inspector General, Medicare Hospices Have Financial Incentives to Provide Care in Assisted Living Facilities (2015), available at: http://oig.hhs.gov/oei/reports/oei-02-14-00070.pdf. Last accessed March 9, 2015.
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