Short Term: There are several proposals that have already been shared with CMS that could be implemented immediately to address the issue of “phantom” or “phony” hospices such as:
- Impose a moratorium on certification of new hospices in the states and localities that are experiencing rapid and unwarranted growth. (Current growth activity is most prevalent in AZ, CA, NV, and TX).
- Increase scrutiny of instances where multiple hospices co-locate at a single address and/or multiple hospices operate under the direction of a single administrator. These hospices should be given careful review relative to licensure and certification.
- Increase frequency of surveys for new hospice providers and survey oversight to ensure hospices have the capacity to deliver all levels of care ((Routine Home Care, Continuous Home Care, Inpatient Respite Care, General Inpatient Care)
- Prohibit “virtual” certification of any new hospices by accrediting organizations
Longer Term Recommendations: Ensure hospices and their providers who are striving to provide quality care have the qualifications, tools, resources, and opportunities to provide the highest quality care.
Billing patterns: Enforce current CMS and accrediting bodies’ rules and regulations that impose civil penalties for inappropriate billing or other infractions