Staff Education an Anchor Amid Widespread Hospice Audits

Hospices need a three-pronged approach to prepare for, respond to and appeal audits as more providers come under a wider regulatory microscope.

A wide swath of auditing activity has ramped up in the hospice space as regulators seek to improve program integrity and quality oversight. More than half of hospice providers reported having multiple types of audits within a six-month span in a survey earlier this year.

This trend means that hospices have increasingly been preparing for or addressing several audits at different phases of the process, according to Jason Bring, co-chair of post-acute and long-term care at the law firm Arnall Golden Gregory LLP (AGG).

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“Audits are now a normal part of business for hospices and home health agencies,” Bring said during the podcast. “Having an audit with denials is really routine at this point in the industry. The auditors are coming in and looking for any reason to deny and then rubber-stamping the denials that were done at the lower levels. You expect and think that they’re going to take a fresh and fair look at things.”

Supplemental Medical Review Contractor (SMRC) and Targeted Probe and Educate (TPE) audits are among the most common types of audits that hospices undergo simultaneously alongside others.

Responding to and appealing these types of audits has become a more time- and resource-intensive process with potential effects on hospices’ operations and margins, according to Bring. Hospices need to have a detailed approach when examining an audit notice in order to understand how to respond, particularly in SMRCs, he added.

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Having ongoing, internal clinical documentation and billing review processes is key to both avoiding and responding to the common red flags on auditors’ radars, which often hinge on around patient eligibility and services related to their terminal condition, Bring indicated.

“SMRCs used to be a little bit kinder and gentler, but now are more serious,” Bring said. “Audits have a lot more danger potential because they’re taking away your money, potentially hundreds of thousands of dollars. You need to protect yourselves as much as possible from the audit risk, and doing these routine checkups is super important.”

Auditing readiness and responsiveness are significant parts of not just compliance, but also sustainability, said Megan Turby, vice president of quality and compliance at Gulfside Healthcare Services.

Two large beacons that remain a constant in compliance are staffing education and documentation, but hospices’ approaches to each of these may need revamping, Turby stated.

“The audits start and they do not stop,” Turby said during a recent podcast. “One of the biggest things I’ve taken away from all of it is to think of auditing prep as survey readiness. You want to have good education in place. You want to see [staff] paint the picture. You’re supporting everything on the backend in the background to be paid properly and defend what you’ve done. You want to be ready all the time.”

Gulfside Healthcare Services, a nonprofit, provides hospice, home health and palliative care from 11 locations across two counties on Florida’s west coast near the Gulf of Mexico. The hospice provider recently underwent an audit appeals process.

Staff need a firm understanding around the potential red flags on regulators’ radars and how to avoid common compliance errors in their roles, Turby stated. Compliance training should be focused on staff’s overall responsibilities alongside the larger bottom line of quality, she said.

Data is paramount to both a hospice’s audit response and preparedness, according to Dr. Lisa Barker, chief medical officer at Gulfside Healthcare Services. Documentation discrepancies can even among interdisciplinary teams as they report on a patient’s condition, Barker stated.

“One thing we saw that judges brought out is sometimes there was a discrepancy between what the nurse documented and what the nurse practitioner documents in a face-to-face [visit],” Barker said. “The big reason for that is because at the time when those notes were constructed the patients can have a change in condition. [It’s] really going back to your team and trying to understand what the discrepancies are. Make sure you explain that in your [physician] narrative, that’s very important.”

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