Increasing audit activity combined with certain decreasingly favorable audit appeal outcomes has resulted in hospices appealing audit results beyond the administrative law judge phase and into federal court. In this episode,...more
Host Jonathan Porter welcomes to the show Husch Blackwell partner Bryan Nowicki, a Madison-based member of the firm’s Healthcare group, to discuss payment suspensions involving the Centers for Medicare & Medicaid Services...more
Hospices that have gone through audits are familiar with certain recurring reasons why auditors deny claims. Two common reasons are the lack of support for a six-month prognosis and the insufficiency of the physician...more
CMS recently expanded its Provisional Period of Enhanced Oversight, or PPEO, in Arizona, California, Nevada, and Texas, and its enforcement activities nationwide appear more aggressive. In this episode, Husch Blackwell’s Meg...more
It’s our first podcast of 2025 and we wanted to start the year out with some reflections. Join Husch Blackwell’s Meg Pekarske and Bryan Nowicki as they each share their biggest surprises and victories of 2024 and what is on...more
The United States Supreme Court recently overruled decades-old precedent that favored an administrative agency’s interpretation of ambiguous statutes. This seismic shift in the role of the judiciary will affect every...more
Hospices that have been audited have to decide how to address any alleged overpayment identified by the auditor, whether through a voluntary repayment, recoupment, or applying for an extended repayment schedule. CMS recently...more
UPIC activity is picking up, and the UPICs are reviving some old tactics. In this episode, Husch Blackwell’s Meg Pekarske and Bryan Nowicki continue the discussion on these trends which include extrapolation, Medicaid nursing...more
UPIC activity is picking up, and the UPICs are reviving some old tactics. In this episode, Husch Blackwell’s Meg Pekarske and Bryan Nowicki discuss these trends which include extrapolation, Medicaid nursing home room and...more
Recovery Audit Contractors (RACs) have played a relatively limited role in the hospice space, often overshadowed by UPICs, SMRCs, and Center for Program Integrity audits. In this episode, Husch Blackwell’s Meg Pekarske and...more
Hospice Targeted Probe and Educate reviews (TPEs) continue to be initiated all over the country. That means it’s time to check in with Husch Blackwell’s Hospice team on the latest developments. In this episode, Meg Pekarske...more
Five years ago, the U.S. Department of Health and Human Services Office of Inspector General (OIG) initiated audits of 13 hospices and published its findings in 13 separate reports. It appears that the OIG is at it again, as...more
Centers for Medicare & Medicaid Services (CMS) devised a “Special Focus Program” to identify poor performing hospices and help them improve through more frequent surveys and technical assistance. CMS would also impose...more
CMS has criticized hospices for underutilizing general inpatient care (GIP) but has also specifically targeted GIP claims for audit and medical review. In addition to CMS’s standard tools for reviewing GIP claims, such as...more
While not new, the number and scope of Targeted Probe and Educate (TPE) reviews have soared to new heights. At the same time, more hospices are facing the uncomfortable position of moving to a second and sometimes third round...more
A study published by NORC at the University of Chicago, a nonpartisan research organization, concluded that the Hospice Benefit saved Medicare $3.5 billion in 2019. The data behind that figure, and the study’s related...more
The Home Care 100 Leadership Conference is an annual gathering of top leaders and innovators in the hospice and home health community. Presentations and informal discussions address the current state of the industry and what...more
Recently, there has been an uptick in contractor participation at the ALJ stage of hospice audit appeals. This development poses unique challenges and new advocacy opportunities for providers. In this episode, Husch...more
COVID-19 remained a substantial obstacle to hospices’ efforts to comply with quality data reporting obligations in 2021. Those challenges resulted in a number of hospices receiving notices of a 2% Medicare payment reduction...more
For the last two-and-a-half years, hospices and other providers have been using billions in Provider Relief Fund (PRF) payments to prepare for, respond to and recover from the COVID-19 pandemic. The Office of Inspector...more
In a prior podcast, we alerted you to the Office of Inspector General’s (OIG) nationwide review of hospice beneficiary eligibility. The OIG has begun sending out requests for records to hospices across the country. In this...more
The core of most hospice audits has been, and continues to be, whether the medical record supports the patient’s hospice eligibility. In this episode, Husch Blackwell’s Meg Pekarske talks with Bryan Nowicki and Zaina Niles...more
Unified Program Integrity Contractor (UPIC) audits are on the rise, and the UPICs are embracing the full array of enforcement tools at their disposal. In this episode, Husch Blackwell’s Meg Pekarske and Bryan Nowicki discuss...more
As audit activity escalates, hospices are getting increasingly familiar with the alphabet soup of audits and auditors, including OIG, UPIC, CMS, CPI, SMRC, MAC, TPE and more. Unfortunately, there are times when hospices are...more
The Office of Inspector General (OIG) recently announced that its 2022 work plan for hospices will include a nationwide review of hospice beneficiary eligibility. In this episode, Husch Blackwell’s Meg Pekarske and Bryan...more