Jim’s Notebook: Luck of the Draw in Hospice Audits; ‘I Want to Die Here’

I am writing to you this week from Arizona’s beautiful Superstition Mountains in the Sonoran Desert, where I am helping my dad out after a surgery. The scenery is lovely, but it’s pretty hot down here compared to my home in Chicago.

If you haven’t checked out my latest Inside Hospice post – titled “I Want to Die Here” – please take a look. I wrote it after seeing heavy metal band Converge perform, but hopefully it will resonate with metalheads and non-metalheads alike.

I want to highlight a great conversation I had with Tami Johnson-White, the new chief compliance officer for St. Croix Hospice in Minnesota, and share some of her thoughts that didn’t make it into my Hospice News article. Tami had some great insights about the importance of organization-wide collaboration to support compliance, transparency and growth.

She also had some very interesting thoughts about the way the federal government’s fraud-busting efforts affect legitimate providers and how they can navigate that. Her comments come against a backdrop of intensifying anti-fraud efforts from the federal government, with a task force recently suspending 447 hospices in California. The organizations are suspected of fraudulent activities totaling more than $600 million.

Here’s that supplemental material from my interview with Tami Johnson-White:

Do you think that the government’s efforts to fight fraud in the space are affecting legitimate providers?

It’s affecting all providers. I think the thing that I’m seeing most that is potentially affecting the good hospice providers is something that’s also affecting the bad hospice providers.

We see variations by auditor — whether it’s a [Medicare Administrative Contractor (MAC)] or a managed care company or anything else — that they do not interpret the regulations in the same way, and so much so that it is not even the same interpretation within an entity. So it is about who you got in the draw and what they believe.

That’s a strong concern for a good hospice provider, and it’s even harder on those who are doing a poor job. I think the other thing that is very hard is that producing packets and going through the process is expensive and time consuming and duplicative. And the reason I say duplicative is that we have some MACs who request the same patient’s records multiple times. So they’ve reviewed it once; they’ve made a decision. Two months later, they request it again — again the same packet, the same patient reviewed over and over and over again.

That duplicative review is very difficult, and it forces every organization to spend more time dedicated to the extra resources to meet the review process, instead of focusing on care delivery.

We have to go through audits, but they should be measured and controlled. They should aggregate the results so that they can say, “Hey, you know what, they’re doing good. Let’s look at them again in a year, instead of being a constant process that’s going on every month without end.”

I will say that with a caveat: they pretty much stop reviewing mid-November through December in many instances, so that they can take their holiday breaks and then resume again in the new year.

How can good hospices navigate some of this?

I believe culture is king. If you truly understand that you are critical to providing quality care, that it is your responsibility to be that beacon during difficult times, then that is the first thing we have to focus on.

Then we step back and learn from the results if we’re having problems in an area, whether it be through audit or through care delivery or anything else. It’s looking at the [Quality Assurance and Performance Improvement (QAPI)] process as something that is alive, not just something you do for the sake of saying you have a QAPI program. Then, make sure that those things you do well are repeatable and done by everyone.

This doesn’t mean people don’t make mistakes, but learning from those mistakes and putting that into practice can help the industry. It certainly can help every one of our organizations to be a strong, good hospice program. We should all be striving to not just be good, but to be great, and to continue that constant improvement and never be a bad actor. I hate that we have to deal with the fact that in the industry there are bad actors, but that means that the rest of us have to step up and just be the best we can be.

As always, thanks for reading, and please share any thoughts or reactions below or in the chat!