The Office of Inspector General (OIG) conducts audits, investigations, and inspections for the U.S. Department of Health and Human Services (HHS) programs which include Medicare-certified home health and hospice programs. The OIG has a work plan that sets forth various projects including audits that are planned to be addressed during the fiscal year and updates the plan monthly (The OIG Work Plan can be found HERE). CMS receives a report of the OIG findings with the OIG’s recommendations and then CMS reviews and responds with what action will be taken based on the report findings.

The OIG released a hospice portfolio report Vulnerabilities in the Medicare Hospice Program Affect Quality Care and Program Integrity in July of 2018, identifying vulnerabilities in the Medicare Hospice Program and made 16 recommendations to CMS to strengthen the hospice program. Hospice providers should be aware that previous hospice portfolios have resulted in an increase in both state and federal criminal investigations. CMS only agreed with 6 of the 16 recommendations made by the OIG which included, the increased use of claims data to identify hospices that “engage in practices or have characteristics that raise concerns.”

Hospice now has 7 active items on the OIG Work Plan with the recent addition of Protecting Medicare Hospice Beneficiaries From Harm:

  1. Medicare Payments Made Outside of the Hospice Benefit
  2. Duplicate Drug Claims for Hospice Beneficiaries
  3. Trends in Hospice Deficiencies and Complaints
  4. Hospice Home Care – Frequency of Nurse On-Site Visits to Assess Quality of Care and Services
  5. Review of Hospices’ Compliance with Medicare Requirements
  6. Medicare Payments for Chronic Care Management
  7. Protecting Medicare Hospice Beneficiaries From Harm

How does the newly added OIG hospice item affect your hospice agency?

The new OIG Hospice item Protecting Medicare Hospice Beneficiaries From Harm is a companion study to the Trends in Hospice Deficiencies and Complaints report (OEI-02-17-00020) in determining the extent and nature of hospice deficiencies/complaints and identify trends by the OIG. Hospice agencies use survey reports and complaint investigations as a means for oversight and the OIG intends to use the survey reports to provide more detail about poor-quality care that resulted in harm to beneficiaries for this study. The OIG includes, they will describe specific instances of harm to Medicare hospice beneficiaries and identify the vulnerabilities in Medicare’s process for preventing and addressing harm.

July 2018 Vulnerabilities in the Medicare Hospice Program Affect Quality Care and Program Integrity: An OIG Portfolio 32 OEI-02-16-00570 https://oig.hhs.gov/oei/reports/oei-02-16-00570.asp

Trends in Hospice Deficiencies and Complaints (OEI-02-17-00020) https://www.oig.hhs.gov/reports-and-publications/workplan/summary/wp-summary-0000211.asp

The OIG Work Plan https://oig.hhs.gov/reports-and-publications/workplan/index.asp