Medicare claims for unrelated services creates serious financial and legal risks for hospice providers — even if they are not the ones who sent the bill.

During recent years, payouts for non-hospice services provided to Medicare beneficiaries have tipped into the billions. Investigators have urged regulators to ramp up oversight of potentially inappropriate billing practices. The vast majority of the time, the hospice is not the organization billing for services outside of the benefit, but these practices and the regulatory response impacts them nevertheless.

This means hospices can expect to see heightened auditing and scrutiny of what costs are deemed “unrelated” to end-of-life care, according to Judi Lund Person, vice president of regulatory and compliance for the National Hospice and Palliative Care Organization.

“We are seeing increased scrutiny of Medicare spending outside the benefit in Parts A, B, or D after a patient has elected their Medicare Hospice Benefit,” Lund Person told Hospice News in an email. “Additional scrutiny about these expenditures is on the rise, and providers should expect to see questions from the [Medicare Administrative Contractors (MACs)] and other auditors about why some items were considered to be unrelated. There will always be gray areas with relatedness based on diagnoses and treatments specific to an individual patient.”

Medicare Conditions of Participation (CoPs) allow health care providers to receive payments for services and items...

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