Extra Scrutiny Needed for Hospice GIP Admissions

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Rhonda Oakes By Rhonda Oakes 
Regulatory Analyst, Change Healthcare
Extra Scutiny Needed for GIP Hospice Documentation

Are you adequately documenting the need for a general inpatient (GIP) stay for your hospice patients? Your organization’s policies and procedures merit a close look following a surprising federal report on GIP stays for Medicare patients during 2012.

Analysis by the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services shows that three in 10 GIP admissions were not warranted for part or all of the stay. In 1% of patient stays, there was no evidence the patient had a terminal condition or elected hospice.

How many of the GIP stays deemed inappropriate were the result of poor documentation? The report showed that hospices did not meet all of the care planning requirements in 85% of the GIP stays it studied.

Inappropriate admissions cost Medicare $268 million in 2012. The study cited hospice providers that double bill for medications under the hospice benefit and Medicare Part D were more likely to inappropriately bill for GIP services.

The OIG made six recommendations that the Centers for Medicare & Medicaid Services (CMS) agreed with. OIG urged CMS to:

  1. Increase its oversight of hospice GIP claims and review Part D payments for drugs for hospice beneficiaries
  2. Ensure that a physician is involved in the decision to use GIP
  3. Conduct prepayment reviews for lengthy GIP stays
  4. Increase surveyor efforts to ensure that hospices meet care planning requirements
  5. Establish additional enforcement remedies for poor hospice performance
  6. Follow up on inappropriate GIP stays, inappropriate Part D payments and hospices that provided poor-quality care

Adequate and comprehensive documentation will go a long way toward justifying GIP stays among your hospice population. When warranted, a GIP stay can help stabilize a patient and control pain so the patient can return home. But as the analysis shows, the benefit can be misused.

Medicare pays no more than $187 for routine hospice care in a patient’s home but pays $720 a day for a GIP stay, according to a news article about the OIG report.

Your organization needs to get serious about adequately documenting the need for each and every inpatient hospice stay. The OIG recommendations may lead to greater scrutiny, so meeting current documentation standards today will help your organization stay in compliance.

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