AI Documentation Seen as a ‘Competitive Advantage’ in Hospice Regulatory Labyrinth

Hospices have leveraged artificial intelligence (AI) documentation tools to help reduce operational and compliance burden during widespread staffing shortages and increasing regulatory scrutiny. However, uncovering the hidden risks and limitations of these technologies is key to gaining a competitive and sustainable edge.

Hospices are navigating an evolving and complex regulatory environment amid program integrity issues in the space. Providers need AI documentation that not only improves workflows, but also aligns with the requirements in the Medicare Hospice Benefit, according to Dr. Brian Haas, a hospice and palliative care physician and national medical director at Ascend Hospice.

Increasing auditing activity in the space has come with high costs and increased workloads for hospice clinicians, Haas said during a Hospice News Elevate podcast. Using AI can help hospices face financial and operational challenges, but careful consideration is needed prior to implementation, he stated. Hass is also founder of Hospice Intelligence, a hospice-specific AI platform that guides clinical decision-making processes such as eligibility criteria and certification documentation.

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“Hospice has grown so dramatically, and is projected to grow even greater,” Haas told Hospice News. “Documentation is going to become your measurable competitive advantage in the future. The more you can document appropriately and well and in the shortest amount of time, that’s a huge factor. What better defense do we have than a great offense? The great offense is capture all of the great work that your clinicians are already doing.”

Dr. Brian Haas Photo courtesy of Dr. Brian Haas
Dr. Brian Haas, hospice and palliative care physician, national medical director for Ascend Hospice, founder of Hospice Intelligence

Demand for automated documentation tools has swelled in recent years. Hospices have used AI in a variety of ways, including visit scheduling, care plan updates, interdisciplinary team notes, medication management and bereavement services, as well as billing, compliance tracking and family communication, among other functions.

Investments in electronic health and medical record systems were identified as a priority among 30% of 103 hospice professionals who participated in Hospice News’ annual Outlook Survey. Meanwhile, 5% of survey respondents indicated that automated technology would yield the largest return on investment in 2026.

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“AI is a hot topic,” Haas said. “Hospices know that this is something that they need to do. It’s a top investment priority because it opens them up for the greatest operational vulnerability. How is it going to help improve your clinicians’ workload? How is that data going to be used?”

AI documentation tools for hospices are in the early stages of development and integration. Emerging AI technologies often lack the capabilities that hospices need to verify eligibility and billing requirements, an issue that can pose regulatory risk, Haas indicated.

More documentation platforms are using generative AI tools, which involve developing text from large language models, he explained. Relying on this type of technology can be problematic, as it often does not involve human input and can introduce compliance risk without an internal auditing system in place, according to Haas.

“We need to have a human in the loop,” Haas said. “Another red flag … is the aspect of LCDs, or local coverage determinants. If you can use an AI tool that’s going to help you to be diagnosis-specific and LCD-focused — that’s going to dramatically improve and safeguard your team. You’re helping your nurses to offload their work burden and protecting yourself when you do get that [audit].”

Moreover, AI systems require continuous training and refinement over time to reduce errors, he said.

Among the propellants of hospices’ technology investments is increased regulatory enforcement. Fraudulent hospice activity has risen in states such as Arizona, California, Nevada and Texas. Georgia and Ohio have also recently joined the mix of potential fraud hotbeds. Regulators are seeking varied avenues to curb fraud, including increased auditing of billing claims.

Billing documentation errors represent one of the most common red flags that bring regulatory scrutiny. Common claim denials and red flags for auditing attention often center around technical documentation errors, eligibility criteria and local coverage determination (LCD) of a patient’s terminal status, as well as recertification.

Hospices spend an average of roughly 200 operational hours responding to an audit, which can result in staffing burden, Haas said. Financial challenges are also an issue. Failing to pass regulatory requirements in a single audit can come with a price tag of upwards of $20,000 in some cases, which can challenge hospices’ sustainability, he stated. AI documentation tools can help hospices safeguard against and prepare for increased auditing activity.

“These are very expensive mistakes to make,” Haas told Hospice News during the podcast. “How do we use AI? How do we harness this? I think over the next five or 10 years, you’re going to see more and more of these real-time audit compliance processes. That gives you an opportunity to really give pause and make sure that it’s appropriately done and has been vetted by a clinician.”

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