Subscribe to RSSIt is the end of the year. It is the end of the first decade of this not so new anymore century. We can’t resist the temptation to make a list of the Top Ten Hospice Regulatory Challenges of the Past Ten Years. Here they are - in no particular order:
1. Complying with the HIPAA Privacy Rule
2. Complying with the HIPAA Security Rule
3. Traveling patients, discharge for cause and nurse practitioners
4. Understanding the proposed CoPs and getting ready for the new ones
5. Complying with the new CoPs
6. CR5567
7. Figuring out how to deal with ADRs and the Medicare Appeals process
8. Certification and recertification and physician narratives
9. CR6540
10. Learning the new alphabet soup of payment scrutiny: MACs, RACs, MICs, ZPICs, QIOs
The list is not exhaustive but highlights some of the bigger challenges. It was a lot to deal with in 10 years and, at the same time, try to care for patients and their families.
It is hard not to wonder what the next ten years will be like - and impossible to predict. On the immediate horizon we know that HIPAA has reared its ugly head again, CR6540 still needs to be dealt with, many hospices continue to struggle to meet the requirements of the not so new CoPs and there is a health reform bill with implications for hospice and increased scrutiny that is likely to pass. And there are all these new or evolved Medicare contractors poised to pounce and make things harder than ever. RAC Assistance for Hospice has received some “intel” from hospices in different parts of the country regarding ZPIC and QIO audits as well as scrutiny of Medicaid payments. While the RACs continue to focus only on hospitals and DME suppliers, it appears the RHHI/MACs, ZPICS, MICS and QIOs are not ignoring hospices. Who are all these contractors and where did they come from? Given that they are all looking at essentially the same thing (documentation of patient eligibility) we will spend some time early in the new year trying to sort them all out.
