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National End-of-Life Organizations Release Consensus Statement on Hospice, the Medicare Hospice Benefit, and Key Issues for the Future
Date:1/8/2009

a hospice physician or advanced practice nurse to personally visit the patient to determine continued eligibility after receiving hospice care for 180 days and, at each subsequent recertification and to attest that such visits took place. In addition, re-certifications should include a brief narrative describing the clinical basis for the patient's terminal prognosis. With regard to hospices with very long lengths of stay, fiscal intermediaries already have existing responsibility to monitor patients' continuing eligibility. Special consideration should be given to the unique issues facing rural and small hospice providers in assessing the impact and implementation of such measures.

Recommendation #2b: The Secretary should direct the OIG to investigate the prevalence of financial relationships between hospices and nursing facilities that may represent a conflict of interest and influence admissions to hospice, differences in patterns of nursing home referrals to hospice, and the appropriateness of hospice marketing materials. The Secretary should make this information available through data use agreements.

With increased utilization of hospice care and growth in the number of providers, it is prudent to encourage appropriate local, state and federal government entities to review financial and contractual relationships between hospice and other health care facilities that may give the appearance of a conflict of interest and potentially influence referrals to hospice. If any instances of fraud and abuse are discovered, they should be immediately reported to the appropriate authorities. In addition, appropriate resources should be directed to undertake more timely and regular surveys of hospice programs, at least as frequently as every three years. Such surveys should be undertaken by highly trained and competent governmental professionals using the recently revised conditions of participation in mind.

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SOURCE National Hospice and Palliative Care Organization
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