Hospice Law and Beyond

In today's episode, Meg talks with Chris Comeaux, President/CEO of Teleios Collaborative Network. Formed in 2017, TCN is an organizational model that allows its 9 non-profit hospice members to maintain their local identity with the support and resources of a larger organization. With years of leadership experience under his belt, Chris provides unique insight into the trends he currently sees, including innovation, and how the hospice industry can prepare for future.

As Bryan comments in today's episode, "preparation brings peace of mind." It is increasingly important to be prepared as government visits seem to be on the rise. The FBI, OIG and DOJ appear to be knocking on hospices', hospice employees' and hospice patients' doors more often. Listen as Meg and Bryan talk about what hospices should do to be prepared and appropriately respond if and when the government shows up.

This week’s episode features Tim Bowen, President and CEO of Care Synergy, which is comprised of five non-profit hospice affiliates in Colorado. Through our conversation, Tim shares both his passion for community based hospice care and thoughts on how hospices can innovate their way into the future. From competitive advantages, better communication, and new technology, such as self-driving cars, Tim talks about how non-profits can be poised for success as the carve-in to Medicare Advantage looms.

CMS recently released a final rule regarding forthcoming changes to 855 enrollment and revalidation applications, aimed at identifying individuals and entities who pose a risk to the Medicare/Medicaid programs. As Part A providers, hospices eventually will be required to comply with this rule and provide information regarding “affiliations” and any “disclosable events” associated with such affiliations. Listen as Meg and Karla breakdown the rule and what proactive actions hospices should consider taking now.

Reinhart analyzes the AseraCare case through its unique lens of representing hospices throughout the country for over 20 years.  While ostensibly a federal False Claims Act (“FCA”) case, the court’s ruling may have a broad application that benefits hospices in other enforcement contexts, including audits and other medical review.  The court’s specific interpretation of the Medicare Hospice Benefit can also guide hospices’ day to day operations.

This week, I talk with Amy Cannizzo-Brennan, the Vice President of Excellence/Corporate Compliance Officer of Trustbridge. Amy shares how she came to the hospice industry (which includes a brief stint as a dog groomer) and what has made her successful in her role, including keeping up with regulations and appropriately assessing risk. With a focus on compliance, Amy and I discuss some of the biggest changes and issues currently impacting hospices.

In this episode, I sit down with Karen Carrig, President, and CEO of Rainbow Hospice, to talk about her experiences in the hospice industry. From hiring good people and supporting staff education, to building relationships and investing in compliance, Karen provides her insights on what makes a provider successful in today’s world.

In this week’s episode we tackle hospice physician relationships. While nothing has changed in terms of physicians being critical members of any hospice organization, the government is becoming more focused on the roles these physicians play beyond direct patient care. From robust certification/recertification requirements to defending audit results, the stakes are higher for hospices, and in turn the expectations are greater for medical directors and other hospice physicians. We discuss the importance of precise contracts for outlining physician duties and corresponding compensation. Beyond this podcast, stay tuned for updates on our forthcoming medical director and other hospice physician contract templates, which may be a good starting point for your organization.

It may be summer break for some, but not for CMS contractors! There seems to be quite a bit of audit activity throughout the country, and in this episode we discuss two types of audits we are seeing (Center for Program Integrity and UPIC Pre-Payment Audits). We also provide an update to Episode 2 regarding SMRC audits as results from Round 1 come in and Round 2 requests begin.

OIG made a splash with two eye-catching reports yesterday that focus on “risks” to Medicare hospice beneficiaries. Reinhart trio, Karla, Bryan and Meg, peel back the layers and pose questions that put these reports into perspective. Despite the reports’ shortcomings, Reinhart suggests how CMS can use these reports to bring about positive change.