Your staff may be missing an important risk management opportunity if a recent OIG report about hospice nursing home patients isn’t on your facility’s radar screen.

An OIG Memorandum Report found that 82 percent of all hospice claims for nursing home residents failed to meet at least one Medicare requirement. According to Mary Michal, these included failure to meet care planning requirements or providing fewer services than set forth in the plan of care.

F309 interpretive guidance:

As such, if your nursing home cares for hospice patients, what does this have to do with your nursing home? The F309 interpretive guidance says about nursing homes coordinating care with the hospice and having a coordinated plan of care. Meg Pekarske has worked with nursing facilities that have been cited because surveyors could not make out by looking at a resident’s care plan that the person was on hospice.

What you should do to safeguard yourself:

According to Pekarske, the best way to protect yourself against hospice-related shortfalls is to be strategic about selecting a hospice that the facility staff feels comfortable with. For instance, the hospice should be responsive to patients’ needs, involved in care planning and understand the nursing home business and regulatory requirements.

Pekarske suggests that if surveyors choose a patient to review, the hospice should be there to answer the surveyors’ questions.

She further adds that the nursing home interpretive guidance for F309 talks about surveyors referring a hospice to its survey agency when they don’t see the expected coordination of care. Hence the hospice staff would want to be there to demonstrate that they’re meeting the requirements so that the nursing home surveyor does not make that referral.

Word of caution: Not that contracting with too many hospices can make coordinating care difficult.