When hospice providers are being investigated not just by CMS but the FBI, the stakes for compliance are higher than ever.
In May of 2024, the federal law enforcement agency placed its spotlight on the rising number of complaints about hospice fraud, in which hospices participate in signing up seniors for care without the seniors’ knowledge. Integrity concerns are in four states: Arizona, California, Nevada and Texas. The mechanics vary but the end result is the same: hospices getting paid for services they either did not provide, provided at a substandard level or had no authority to provide at all.
“The resurgence of hospice program integrity scrutiny after recent media reports highlighted fraud, specifically in four states, sparked in-person visits by CMS to every Medicare-enrolled hospice, and found about 400 being considered for administrative action,” says Courtney True, BSN, RN, and Strategic Account Executive of Homecare Homebase.
This attention from law enforcement, government agencies and the press is not going away. Therefore, hospice providers must better prepare for audits and oversight. This can be a challenge, especially when it comes to documentation. This article will outline the top three strategies to drive compliance and audit preparedness in hospice care.
Strategy #1: Evaluate your staff’s documentation habits
Everything begins at documentation, and that means hospice providers have to establish a baseline for the accuracy and speed of their documentation. If documentation is unreliable or simply not up to standard, hospices must be able to determine why. Amedisys tackled documentation challenges by combining Homecare Homebase with a speech recognition solution.
“We started out with a really simple question, which was to ask, ‘Why are my physicians not documenting?’” says Amy Moss, SVP of Clinical Operations for Hospice and SVP of Palliative Operations at Amedisys.
For some, the answer was that physicians did not understand how the documentation needed to be completed.
“That’s an educational piece, and we fixed that,” Moss says.
For other physicians, the challenge was more practical: they were either slow typists or had bad handwriting.
“They would just type the minimum, which was good for them, but bad for the record,” Moss says. “That meant from a quality perspective, we couldn’t really tell what was going on with the patient at that moment in time, which then impacts what happens down the road when those claims were being audited in both an internal and an external fashion. We were finding that we were having our revenue at risk because of that activity. It wasn’t meeting minimal standards. Those two were huge concerns for us.”
But there is another reason why documentation might lag: clinicians might not see it as important. To fix that, hospices have to go deeper.
Strategy #2: Teach the “why”
When Amedisys found gaps in their staff’s documentation, they saw different reasons for those gaps. While technology, time-management or education fixed some of the gaps, there were also philosophical components that needed to be addressed. Clinicians didn’t realize why documentation was as important as it is or weren’t focused on the problems that a failed audit could cause.
“Patient care is at the bedside, and I believe, as a clinician myself, that the more your bedside staff know and understand the ‘why’ — the expectations, metrics, and requirements of their role — the more they can buy in and support the process, which ultimately means providing the best possible care for their patients,” True says. “That, at the end of the day, is really the goal of anyone working in patient care.”
Explaining the reasons behind the work is useful for back-office workers too, True says, as these workers also hold a key piece of audit success.
“I think the answer is similar for the back office – a collective buy-in to understanding ‘the why’ behind tasks and requirements leads people to better understand how their role matters in the big picture and how they are contributing to the larger mission,” she says.
Strategy #3: Make changes to empower staff
Change management is a process. It takes time. As hospices make changes to empower their staff members, the key is to find quick wins, Moss says. She recalls how changes to documentation started with a move from physical technology to cloud-based technology, making it easy for clinicians to “just talk.”
“We started out with a product like that — the Cadillac version when I just needed the little Volkswagen piece,” she says. “That was a cloud-based HIPAA-compliant speech recognition tool. The change challenge was with that particular group of physicians. But over time, you’ve got to have a champion that sticks with it. And you’ve got to have clearly defined goals along a roadmap of what we’re trying to accomplish. You can’t just throw it all at them at once.”
For Amedisys, that champion is Homecare Homebase.
“From the very beginning, Homecare Homebase has checks and balances in place to ensure the patient receives quality care and the hospice is in compliance with hospice regulations and CoPs,” True says. “For the field nurse, they have required documentation, like the HIS assessment, to finish before a visit can be completed. Our assessment structure gives customers the flexibility to add in any necessary specifics they need as an agency for state or program-specific requirements for additional compliance.”
HCHB offers tools for documentation, such as assessment forms customization that tailors care to patients. Their care-planning tool for hospice, the Person-Centered Care Plan, satisfies the clinician’s need to adapt their care plan based on the patient, True says, and also demonstrates the care provided at any time to a hospice patient on service for a surveyor to review.
“I think HCHB is a great partner — they are very receptive to changes and pivots,” Moss says. A patient with terminal cancer, for instance, has a documentation template that is different from a patient with dementia. “There’s a template that is meant to gather necessary information, but it’s also meant to try to prompt the user, to make sure they ask those questions and capture that important information.”
Making the move from paper to technology, or from hardware to cloud-based technology, is a major help for care staff. Explaining the “why” gives the intellectual backing. And receiving ongoing support from a technology partner is the final piece.
“What is particularly valuable about the relationship with Homecare Homebase is that we have the ability to customize to what we feel as an organization is most meaningful to us,” Moss says.
“From an audit oversight perspective, that allows me to have checks and balances about how well we’re using the tool. Is it being used as intended all the time or just 10% of the time? That gives me an opportunity to go and close those gaps.”
HCHB delivers powerful new tools and intuitive software that’s easy to learn and use. From scheduling, routing, patient notes and reporting to intake, approvals, billing, compliance and payment, we give you everything you need to boost productivity and profits while empowering exceptional patient care. To learn more, visit hchb.com.