LeadingAge, along with the National Association for Home Care and Hospice, the National Hospice and Palliative Care Organization, and the National Partnership for Healthcare Innovation, are partnering to collect information on various audits of hospice claims to share with the Centers for Medicare & Medicaid Services (CMS). Earlier this year, the associations sent a letter to CMS outlining our concerns and there was a mutual desire to focus on correcting issues related to the audits.

We are asking for LeadingAge members to help to collect examples of these audit issues by completing this survey by October 31 (with no protected health information), particularly of technical denials. We are keeping all responses confidential and no provider information will be shared.

Technical denials are those where the review entity denies all or a portion of payment due to a hospice not meeting the technical requirements of the certification of terminal illness including the face-to-face and/or the Medicare hospice election statement, e.g., attestation requirement or certifying physician signature in the wrong place on the certification of terminal illness, Medicare hospice election statement not including specific terms/statements such as “palliative rather than curative nature” or the local Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO) telephone number not present on the election statement. While we are primarily looking for technical denial examples currently, we also welcome examples of claim denials more substantive in nature.

We will use this initial survey response to discuss common issues and develop solutions with CMS, but we will continue to be interested in hearing about hospice audit burdens and challenges from our members on an ongoing basis. You can direct those specific issues to Katy Barnett (kbarnett@leadingage.org) and Mollie Gurian (mgurian@leadingage.org).