OHIO HOSPICE GIP UNDER SCRUTINY

• The Office of Inspector General (the “OIG”) concludes that in 2012, hospices overbilled Medicare $268 million for general inpatient care.
• Ohio, Arizona, and Florida stood out with the highest level of inappropriate general inpatient care (“GIP”) in the OIG’s sample.
• Ohio hospices should be prepared for increased scrutiny of GIP stays.

Last month, the Office of Inspector General (the “OIG”) released a new report describing how in 2012, hospices overbilled Medicare $268 million for general inpatient care (“GIP”). GIP is the second most expensive level of hospice care and is meant for patients who need a short-term inpatient stay in either a hospital, hospice inpatient unit, or skilled nursing facility for symptom management and pain control that cannot be handled in other settings. According to the OIG, the overbilling for GIP care commonly occurred due to hospices electing GIP care, but beneficiaries not having uncontrolled pain or unmanaged symptoms.

Ohio stood out to the OIG as one of the worst offenders of inappropriate GIP billing, along with Arizona and Florida. In Ohio, over half of the sample GIP stays looked at by the OIG were deemed to be inappropriate. The OIG’s examples of inappropriate GIP stays included a beneficiary receiving GIP care despite his symptoms being controlled, requesting bingo night on the first day of GIP care, and yet remaining in GIP care for 14 days, costing Medicare more than $10,000. The OIG also found that for-profit hospices were more likely than other hospices to bill inappropriate for GIP care.

Given these findings, the OIG has recommended that the Centers for Medicare & Medicaid Services (“CMS”) (1) increase its oversight of hospice GIP claims; (2) ensure that a physician is involved in the decision to use GIP; (3) conduct prepayment reviews for lengthy GIP stays; (4) increase surveyor efforts to ensure hospices meet care planning requirements; (5) establish additional enforcement remedies for poor hospice performance; and (6) follow up on inappropriate GIP stays. CMS agreed with these recommendations.

Given the OIG’s findings and CMS’ agreeance with the proposed changes, hospices should expect increased scrutiny of GIP billings and implement proactive measures now, such as internal and external monitoring and auditing, to ensure their GIP billings are appropriate and will withstand further review.