Greater transparency in staff evaluation processes and increased education will be keys to navigating a range of hospice compliance challenges in a post-pandemic landscape.
Since the COVID outbreak struck, hospices have contended with changes in regulatory requirements around telehealth utilization, emergency preparedness and infection control and prevention. Ramped up auditing activities and program integrity oversight have also occurred alongside the public health emergency’s end in May.
This evolving mix of hospice regulation has placed staff oversight at the forefront of ensuring compliance, according to Christie Piland, director of education at Caris Healthcare.
The ability to monitor and educate staff on their roles and responsibilities in compliance will be a key for hospice sustainability and quality heading into 2024, Piland said at the National Hospice and Palliative Care Organization’s (NHPCO) Annual Leadership Conference in Little Rock, Arkansas. Having a window of transparency built into staffing processes will play a large role in ensuring compliance, she stated.
“We will always have standards, policies and procedures that oversee our programs,” Piland said. “We should always be screening and evaluating employees, physicians, vendors and other agents. We should provide ongoing communication, education and training on compliance issues. We need to ensure we have a process to monitor audits and have an internal reporting system. If someone is noncompliant, we need to ensure we have a disciplinary process. We need to ensure we have investigations and appropriate remedial measures.”
Caris Healthcare provides adult and pediatric hospice care to more than 40,000 patients and families across 28 locations in Georgia, Missouri, South Carolina, Tennessee and Virginia. Additional services include palliative care, a veterans program and care coordination.
Transparency around hospice staffing and ownership is a large focus of program integrity efforts among regulators, Piland stated.
Among the proposed regulatory changes for hospices to monitor is one that impacts screening of hospice ownership. On Wednesday, the U.S. Centers for Medicare & Medicaid Services (CMS) finalized its home health rule for 2024 containing a new policy that will require anyone who holds 5% ownership or more in a hospice to submit a criminal background check, including fingerprints.
The rule requires providers seeking Medicare certification to report any changes in ownership and ensure the “highest level of screening,” possible, Piland said. The rule also clarifies definitions around hospice leaders, as well as how noncompliance could impact Medicare billing capabilities, she said.
“CMS [is] increasing hospice provider application screenings to the highest level, which would include fingerprinting all 5% or greater hospice owners,” Piland said. “They’re also providing clarification around what a ‘managing employee’ is. This is included in the standard requirements for establishing and maintaining Medicare billing privileges. Their recommendation is that it would include the administrator and medical director of hospice agencies.”
Along with hospice leaders, transparency around interdisciplinary teams and back-office staff will also be crucial to compliance next year, according to Sylvia Singleton, corporate compliance officer at Caris Healthcare.
Ensuring quality and compliance will include the ability to have visibility into various clinical and billing practices, including instilling a “checks and balances” system around internal processes, she stated.
“Regulators’ key priorities are ensuring quality care and preventing patient harm,” Singleton said at the NHPCO conference. “So it’s building transparency and access to information that promotes accurate and effective billing practices and quality care. We’ve heard the importance of documentation numerous times, but it’s following up with how to identify that something is a problem so you can make corrections.”
Having a window into potential problem areas across an organization is an important part of hospice compliance, Singleton said. This includes instilling internal standards that help flag issues among billing and documentation processes is part of hospices’ roadmap to compliance, she added.
“Providing greater transparency includes making sure visits were made, that levels of service were accurate and you’re submitting eligibility criteria,” Singleton stated. “You have lots of opportunities to ensure your practices are on target. All of these things are monitored and tracked. It’s looking at your own data analysis and developing your own reports and processes to monitor it. It’s about your internal standards.”