New Partnership and Hospice Regulatory Compliance Program Announced

(August 20, 2018)—To address the myriad regulatory complexities and increased levels of scrutiny unique to the hospice provider community, the National Hospice and Palliative Care Organization (NHPCO) has launched the first component of the organization’s new comprehensive compliance program; it will roll out the program more fully in 2019. The organization’s new Hospice Compliance Certificate Program is a first of its kind from the organization and approaches regulatory compliance with specificity.

“Building on our expertise in the field and our extensive collection of regulatory resources, NHPCO’s new compliance program will help good hospices move to great, struggling hospices to improve, and to get hospices that are not committed to operating a compliant program to improve or get out of the business,” said Edo Banach, president and CEO for the NHPCO, which says regulatory scrutiny that has focused on the Medicare hospice benefit and hospice providers is likely to continue into the foreseeable future.

In development over the past year, the inaugural offering of the two-day Hospice Compliance Certificate Program will be November 3–4, one of the preconference offerings that are part of the organization’s 2018 Interdisciplinary Conference (the main conference is November 5–7 at the Hyatt Regency New Orleans).

In addition to helping hospice providers achieve the highest levels of compliance, NHPCO is working to help the administration, regulators, media and other stakeholders gain a clearer picture of hospice access and delivery in the U.S., as well as a better understanding of the complexity of compliance within the field. Participants who successfully complete the certificate program will benefit from a detailed review of the federal hospice regulations, including conditions of payment, conducting an internal audit, looking at organizational ethics related to compliance and audit scrutiny. The importance of the Stark law, the Yates memo, anti-kickback statutes, and inducements for referrals and incentives for marketing will also be covered.  

“The two-day course is unlike other offerings; it’s a must for all hospice professionals and offers hospice specific compliance content, up to-the-minute compliance updates, and clear application for their programs back home,” said Judi Lund Person, NHPCO vice president of Regulatory and Compliance.

Continuing education/continuing medical education credit is available for compliance officers, nurses, physicians and social workers. More information about the program can be found here.

In other news from the NHPCO, the organization announced it has partnered with Better Medicare Alliance (BMA), to engage in a mutual collaboration addressing the challenges and opportunities associated with possible policy changes that would “carve in” hospice under the Medicare Advantage (MA) program.

“Whether hospice continues to be ‘carved out’ of Medicare Advantage or is thoughtfully and responsibly ‘carved in,’ our paramount concern is for patients and families receiving hospice care. This dialogue is an important step in assuring that we protect these patients and families,” Banach said.

Under current policy, MA enrollees who elect hospice remain in their MA plan, but fee-for-service Medicare becomes responsible for most services while the MA plan retains responsibility for other services. This fragmented payment arrangement goes against the goal of more care integration, according to the NHPCO. Through ongoing dialogue and a series of convening meetings, NHPCO and BMA will gather input from hospice and palliative care leadership and providers, health plan leaders, policy experts, sponsors and other stakeholders to ultimately chart a course for policy development that will meet the needs of patients, families, providers and payers.

BMA is a nonprofit advocacy coalition of more than 100 ally organizations, including providers, professional associations, aging services organizations, health plans and more than 400,000 senior advocates focused on strengthening Medicare Advantage. For more information about the BMA-NHPCO relationship, visit nhpco.org.