2014 Year-end Hospice and Home Health Update: The Regulatory Landscape for Hospice and Home Health Providers Continues to Change

Houston Medical Times January 2015

Emily E. Bajcsi, Member of the Firm in the Health Care and Life Sciences practice, in the firm's Boston and Washington, DC, offices, and Serra J. Schlanger, Associate in the Health Care and Life Sciences practice, in the firm’s Washington, DC, office, authored an article in the Houston Medical Times, titled “2014 Year-end Hospice and Home Health Update: The Regulatory Landscape for Hospice and Home Health Providers Continues to Change.”

Following is an excerpt (see below for a PDF of the full article—see page 3):

Enacted in early October, the improving Medicare Post-Acute Care Transformation Act of 2014 (“the IMPACT Act”) includes several key changes that affect hospice providers. Beginning in April 2015, all Medicare-certified hospices will be subject to routine survey at least every three years. Prior to the IMPACT Act, the Centers for Medicare and Medicaid Services (“CMS”) required certification surveys of hospices every six years, compared with home health agencies which are required to be surveyed every three years, and nursing homes which are surveyed annually. In addition, in 2013, the Department of Health and Human Services Officer of Inspector General (“OIG”) found that 17 percent of state-surveyed hospices were past due for their six-year survey, leading to concerns about inadequate oversight of hospice compliance with the Medicare conditions of participation and quality-of-care requirements. With this legislation, many hospice providers can expect more frequent surveys that in previous years (those surveyed by private accrediting organizations may already be on a three-year survey cycle).

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