With increasing regulatory scrutiny, home health and hospice organizations are facing increasing pressure to stay ahead of audits, denials and shifting policy priorities.
At the 2025 小猪视频 Growth, Innovation and Leadership Experience (小猪视频), Jason Bring, Partner at Arnall Golden Gregory LLP, and Patrick Harrison, Senior Director of Regulatory and Compliance at National Alliance for Care at Home, discussed the current regulatory landscape, spending trends, compliance challenges and provided strategies for success.
Increasing Regulatory Scrutiny
Regulations in hospice and home health are growing more rigorous, emphasizing fraud prevention and thorough patient documentation.
鈥淲e’re seeing more and more spending on hospice, outpacing home health now,鈥� Bring said. 鈥淲e’re returning to pre-COVID levels with over 50% of our patient base utilizing the hospice benefit.鈥�
Bring highlighted the importance of understanding the MedPAC numbers.
鈥淎ccording to MedPAC, about 2.7 million beneficiaries are using home health in the Medicare fee-for-service benefit,鈥� Bring explained.
Balancing Survey and Audit Preparedness
Organizations must balance survey and audit preparedness to ensure compliance and avoid financial penalties. Many organizations assume that strong survey performance means they are audit-proof but that鈥檚 a misconception.
Bring shared a client鈥檚 experience of receiving a perfect survey but getting a $450,000 denial. Despite the good survey results, the denial came from an audit by a supplemental medical review contractor.
鈥淛ust because you鈥檙e compliant with the conditions of participation doesn鈥檛 mean you鈥檙e meeting the conditions of payment,鈥� Harrison explained.
Consistent and Detailed Documentation
Consistent and detailed documentation is important for hospice and home health organizations when caring for long-term patients with conditions such as Alzheimer’s and dementia.
鈥淭he main focus for me is Alzheimer鈥檚,鈥� Bring noted. 鈥淭hat鈥檚 where we see the most problems with documentation because they鈥檙e on for so long and different caregivers are involved.鈥�
Auditors look for consistency. Copying and pasting notes or making typos can trigger a deeper investigation.
Provisional Period of Enhanced Oversight
The Centers for Medicare and Medicaid Services (CMS) Period of Enhanced Oversight (PPEO) is expanding, and organizations must be vigilant to avoid overregulation and exclusion from programs.
鈥淭he PPEO is quick to jump on an issue and can put great operators in a concerning situation,鈥� Harrison said.
Organizations should monitor regulatory developments closely and begin preparing. Waiting could result in exclusion from Medicare programs.
Proactive Compliance
To thrive in this high-stakes environment, organizations must shift from reactive to proactive.
鈥淵ou never get a second chance to make a good first impression,鈥� Bring said. 鈥淧ackage your records in a very organized format to reduce denials from the start.鈥�
鈥淲e need to document effectively with the mindset of getting paid and train our staff appropriately,鈥� Harrison added. 鈥淜eep yourself from getting denials in the first place, so that you don鈥檛 have to hire consultants and attorneys to go through that process.鈥�
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