Being surveyed to participate in the Medicare program is usually seen as an onerous task by most healthcare facilities, but the hospice community wants to be surveyed more frequently, even if the cost of those surveys comes out of its own pocket.
“It would both be something that the hospice community would welcome and at the same time there would be an associated burden with that, but it’s one that the hospice community would accept, I think, with a great deal of satisfaction because we’ve been asking for more frequent surveys for a number of years now,” said Jon Keyserling, the senior vice president of health policy for the National Hospice and Palliative Care Organization.
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The hospice community has been growing quickly in recent years, with Medicare paying an increasingly larger chunk of payments to those hospices. In its efforts to combat fraud and ensure hospices are meeting the program’s conditions of participation, the Office of Inspector General investigated the Medicare survey process of hospices in 2007, finding that hospices were not surveyed often enough.
In 2007, OIG found that the average recertification survey occurred every nine years. The agency recommended to the Centers for Medicare & Medicaid Services that more frequent recertification surveys become the standard. CMS disagreed then, and again this summer, when OIG followed up on the 2007 report, finding that the frequency of surveys had not improved and once again recommended increased frequency of surveys, suggesting surveys be done every three years, which is the interval used by accrediting agencies approved by CMS.
Those in the hospice community understand that CMS and the states don’t have the resources for more frequent surveys, however, the industry seems ready to step up.
“There is a cost associated with it, but there’s also in basic compliance as well as in any quality improvement program an investment on the part of the healthcare provider to improve their care and their delivery mechanisms, and I think the hospice community is committed to that,” said Keyserling.
One solution would be to require hospices to be surveyed on a three-year basis by one of the accrediting agencies, such as the Joint Commission, said Jay Analovitch, managing partner of operations at CURO Healthcare Solutions, an operator of seven hospice communities across 10 states.
“In our opinion, this is a good use of monies as greater cooperation and review and mutual oversight would be accomplished by raising best practices for all hospice agencies to a national standard,” he said.
Paying out-of-pocket for an accrediting agency to conduct surveys would be something Mission Healthcare, which operates hospices and home care services in southern California, would be willing to do if it was the standard and all hospices were subject to the same scrutiny, said Kerry Pawl, one of Mission’s founders and owners.
While paying out-of-pocket will be a strain for many hospices, the benefits far outweigh the financial burden, said Malene Davis, chief executive officer of Capital Caring, a provider of palliative care and hospice services in the greater Washington, D.C. area.
“What a survey does for you is it tightens the organization back up,” she said. It is a learning opportunity that helps the hospice continually be the best operationally, and for patients and their families.
“The public needs some guarantee that when they sign up and when they give the right to their Medicare benefits to the hospice, they must have some … assurance that this place meets the basic criteria of what a hospice is supposed to be,” she said, “and the only way you can guarantee that is someone coming in and inspecting.”