CMS Expands Enhanced Oversight of Hospice Providers: Prepayment Review, Heightened Risk and Rising Revocations
Healthcare attorney Shalyn Watkins wrote an article for the American Health Law Association about the Centers for Medicare & Medicaid Services' (CMS) continued focus on enforcement against hospice providers, exemplified through the expansion of its Provisional Period of Enhanced Oversight (PPEO) and related Expanded Prepayment Review (EPR). PPEO and EPR aim to combat fraud, waste and abuse in the hospice care industry, and CMS broadened their scope to include states that it says have seen an increase in hospice enrollment without a corresponding increase in eligible patient population. Under PPEO, CMS exercises heightened scrutiny of claims and operations, particularly in situations involving new Medicare enrollments or changes in ownership; through EPR, CMS suspends claims until it completes its review of them, which creates financial pressures for organizations. The process in both situations can result in claim denials, extended review or revocation of Medicare enrollment – and revocation has been on the upswing, demonstrating the government's willingness to act early and decisively when compliance concerns arise. In her article, Ms. Watkins outlines how the PPEO and EPR regimes work and lists four key takeaways stemming from their expansion, especially for newly covered entities in Georgia and Ohio. The article provides a useful guide to risk management and compliance expectations now that the margin of error has narrowed.
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