Half of Hospices Unprepared for Regulatory Audit

Fewer than 50% of hospices indicated that they were ready for a federal audit or additional document request, according to a recent survey by Optima Health.

As hospices come under increasing regulatory scrutiny, ensuring complete and accurate documentation is a growing concern.

“The quality of a hospice provider’s documentation can determine the outcome of a medical review audit. Documentation content and quality can make or break hospice providers in today’s landscape …,” according to a National Hospice & Palliative Care Organization (NHPCO), documentation webinar.


The US Centers for Medicare & Medicaid Services (CMS) requires complete, accurate, and patient-specific clinical records. Insufficient documentation can affect the payments hospices receive or expose providers to fraud investigations.

A 2018 report from the US Department of Human Services Inspector General cited noncompliance with CMS documentation requirements as a significant contributing factor to improper payments to hospices ranging from $447,000 to $1.2 million.

More than 170 U.S. hospice organizations in the United States responded to the survey, leading to these key findings:

  • 46% of said they lacked full confidence in their ability to survive a CMS audit.
  • 42% said they lacked full confidence that they could effectively respond to an additional document request.
  • 97% reported regular problems in their documentation processes. Sending documentation back to clinicians for correction was the most prevalent problem, experienced by 94% of the respondents.
  • 94% said their clinical documentation systems or process needed improvement.
  • 64% said they had to redo Medicare claims because CMS rejected their documentation.

Hospices reported that documentation problems have had an adverse impact on their businesses, according to the survey. These include challenges with regulatory compliance, reduced staff satisfaction, declines in clinician productivity, and diminished clinician work/life balance.

“The findings show that clinical documentation is a key area of vulnerability for many hospices,” said Josh Pickus, CEO of Optima Healthcare Solutions. “Addressing this vulnerability requires taking a close look at the underlying problems that inefficient documentation is causing, and evaluating how technology, best practices, and other approaches can reduce risk.”

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