Compliance and Regulatory - Directors
The Agency Is Accountable. The Clinicians Are Not. That's the Problem
Hospice compliance gaps aren’t caused by clinicians. They are built into the structure of distributed care. Agencies carry the risk while clinicians own the clinical moment, creating a visibility gap no policy memo can fix.
August 5, 2026 · 3 min read
Understanding HQRP: The History of Hospice Quality
Hospice care, since its inception, has been about compassionate care. However, the underlying mechanisms of how it is paid for and how hospice quality is evaluated have undergone a significant transformation. This shift is part of a broader healthcare movement towards value-based care, moving away f
March 22, 2026 · 6 min read
How to Master the Hospice CBR for Better Compliance
Many hospice administrators are familiar with the hospice PEPPER report. A smaller number of hospice leaders, however, are familiar with its counterpart: the Comparative Billing Report (CBR) and eCBR, the electronic version of the Comparative Billing Report. While the PEPPER provides a general overv
February 1, 2026 · 6 min read
QAPI Documentation: How to Show Your Program is Active and Effective
Hospice leaders often understand that QAPI is required by CMS, but many do not know how to document the program in a way that proves it is genuinely active and effective. CMS surveyors want to see more than binders, charts, or paperwork. They are looking for documentation that demonstrates continuou
December 30, 2025 · 6 min read
How to Collect QAPI Data that Shows What Needs to Improve
In hospice, most organizations understand why Quality Assessment and Performance Improvement (QAPI) is required. What many do not understand is how to collect data in a way that reveals patterns, risks, and opportunities for improvement. QAPI data collection does not mean saving every report, printi
December 29, 2025 · 4 min read
What is the Hospice Quality Assessment and Performance Improvement Program?
A hospice Quality Assessment and Performance Improvement (QAPI) program is the formal system a hospice uses to understand how well it is functioning, where it is at risk, and how it will improve over time. Under 42 CFR § 418.58, CMS requires every hospice to maintain an ongoing, hospice-wide, data-d
December 29, 2025 · 6 min read
AI At the End of Life: Help, Not a Decider
End-of-life decisions are some of the hardest moments any family, clinician, or hospice team will ever face. Even when a patient has had candid conversations with loved ones, the reality of decline can feel different than anything imagined. When there is no advance directive or clear documentation o
November 25, 2025 · 5 min read
The Hospice Initial Assessment: A Foundation for Compliance & Quality
When hospice patients have no family or stable home, care gets complex. This blog explores how teams can respond with compassion, ethics, and creativity.
August 24, 2025 · 4 min read
Government Audits: Extrapolation and its Financial Impact
Hospice agencies are under increasing scrutiny by government auditors. A particularly concerning and financially devastating aspect of government audits is the use of statistical extrapolation. Understanding the extrapolation process is essential for providers to safeguard the financial healthof the
June 30, 2025 · 4 min read
Legal Risks of Retaliation: How to Handle Employee Complaints Safely
When an employee brings forward a compliance concern, they’re engaging in what the law defines as protected activity. This might involve reporting a potential violation of hospice regulations, concerns about Medicare fraud, or even raising issues about unsafe working conditions. These are rights gua
December 10, 2024 · 3 min read
What is a Hospice IDG Meeting and Who Should Attend
The hospice interdisciplinary group (IDG) creates a patient’s plan of care and provides holistic care to the patient, caregiver, and family. Hospice Conditions of Participation require the IDG to “review, revise, and document the individualized plan as frequent as the patient’s condition requires, b
October 13, 2024 · 3 min read
Hospice Interdisciplinary Group (Hospice IDG)
Hospice care is patient- and family-centered, where the patient's and family's preferences and needs drive the care plan. The hospice interdisciplinary group (also referred to as Hospice IDG or IDG), also referred to as the interdisciplinary team (IDT) is a team of healthcare professionals who work
October 7, 2024 · 4 min read
Pay Transparency: What Managers Need to Know
As a manager in hospice care, your role goes beyond overseeing patient care and managing staff. It includes ensuring that your team feels valued and fairly compensated. Pay transparency is becoming a hot topic, and understanding its implications can help you effectively navigate this evolving landsc
August 14, 2024 · 4 min read
Elevate Your Hiring with Powerful Demographic Insights
Creating and using benchmarks to compare your company's hiring demographics against those used by government agencies like the EEOC (Equal Employment Opportunity Commission) is crucial. Benchmarking helps ensure that your company’s hiring practices are fair and compliant with federal regulations. He
August 3, 2024 · 3 min read
What is the Hospice Special Focus Program?
The hospice Special Focus Program (SFP) is conducted by the Center for Medicare and Medicaid Services (CMS). The objective of this program is to identify poor performing hospice agencies, based upon quality indicators, that place hospice beneficiaries at risk. These hospice agencies will then be sub
February 14, 2024 · 3 min read
Hospice Length of stay – active or discharged patients?
Patient length of stay is monitored to detect instances of inappropriate use of the hospice benefit or other deficiencies in the services delivered by the hospice provider. Length of stay is monitored for both very short length of stay as well as for length of stay that is longer than the norm. What
March 22, 2023 · 3 min read
Average length of stay versus median length of stay
Patients are eligible for hospice if they have a terminal diagnosis and a prognosis of six or fewer months to live if their disease runs its natural course. A patient who lives longer than six months can still get hospice care if the medical director or other hospice physician recertifies that the
March 22, 2023 · 5 min read
Using data to support a hospice marketing strategy
Why is data valuable? Like all other business decisions, a hospice marketing plan must be data driven. More progressive hospice agencies have increasingly begun to understand the value of many types of data in supporting business decisions. This includes internal data such as patient EMR data, fin
January 29, 2023 · 3 min read
What is the hospice governing body?
What is the governing body? In accordance with the Conditions of Participation, a Medicare certified hospice agency must have a governing body. The governing body has ultimate responsibility for the hospice agency, including legal and financial authority. Medicare Conditions of Participation require
January 29, 2023 · 2 min read
What is a UPIC audit?
What is a UPIC? Unified Program Integrity Contractors (UPICs) are contracted by CMS to conduct detailed medical review, data analysis, and audits of healthcare providers to investigate possibilities of Medicare or Medicaid fraud, waste, and abuse. While the primary purpose of a RAC or MAC audit is t
January 28, 2023 · 8 min read
What is the TPE audit process?
What is a TPE? A Targeted Probe and Educate (TPE) is an audit program that was rolled out by CMS in 2017. The stated goal of this program is to help providers reduce claim denials and appeals. The TPE works to achieve its goal by educating providers in topics that will help to eliminate common [&hel
January 28, 2023 · 3 min read
What is a SMRC review?
What is a SMRC? A SMRC is a Supplemental Medical Review Contractor. CMS contracts with SMRCs to conduct medical reviews for Medicare Part A, Medicare Part B, and DME providers. SMRCs are contracted through the Center for Program Integrity/Provider Compliance Group Division of Medical Review and Educ
January 28, 2023 · 7 min read
What is the Hospice Quality Reporting Program (HQRP)?
What is the purpose of hospice quality reporting? The Affordable Care Act authorized the establishment of a Quality Reporting Program for hospices. The Hospice Quality Reporting Program (HQRP) was established in 2014. HQRP aims to ensure that the level of quality in clinical care, symptom mana
December 11, 2022 · 3 min read
What is Hospice Item Set (HIS)?
All Medicare certified hospice agencies must submit an HIS Admission and HIS Discharge record on all admissions and discharges from their agency. The report must include all patients, irrespective of payer source, patient age, or location where hospice services were provided. It is recommended that
November 27, 2022 · 3 min read
What is the CAHPS survey?
The CAHPS survey is intended to measure the experience of patients who had died while receiving hospice care and the experience of their primary caregivers. It surveys informal caregivers – usually family members – of the persons who died under hospice care. The survey is a component of the Ho
November 27, 2022 · 5 min read
What is a hospice PEPPER report?
Program for Evaluating Payment Patterns Electronic Reports (PEPPER) is a data analysis report that has been available for hospices since 2012. This report contains claims data statistics based upon UB-04 claims data submissions for a single hospice agency. The statistics are generated for areas that
November 26, 2022 · 6 min read
Understanding the PEPPER Report
The PEPPER report target areas focus on statistics that will identify potential for improper Medicare billing. Comparison to national, jurisdictional, and state percentiles can highlight a hospice agency’s potential need for change to its practices to guard against improper billing. Hospice agencies
November 26, 2022 · 5 min read
What is Hospice Visits in the Last Days of Life (HVLDL)?
HVLDL is an HQRP claims-based measure of the proportion of patients who have received in-person visits from a registered nurse (RN) or a medical social worker (MSW) on at least two of the final three days of life. This metric replaces the HIS-based measure Hospice Visits When Death is Imminent (HVWD
November 13, 2022 · 4 min read
What is Hospice Care Index (HCI)?
HCI is a single comprehensive metric reflecting ten indicators of care delivered during a hospice stay — from admission to discharge. This metric, which is included in the patient Care Compare portal, is intended to provide patients, families, and caregivers with an added metric to support inf
November 13, 2022 · 4 min read
Must every hospice participate in the CAHPS hospice survey?
What is the CAHPS hospice survey? The CAHPS hospice survey is administered to eligible caregivers after a patient’s death to measure the quality of care and communication provided by the hospice. A hospice agency must participate in the CAHPS Hospice Survey to be eligible for its full annual payment
November 7, 2022 · 3 min read
Selecting a CAHPS Hospice Survey Vendor
Why should a hospice agency use a CAHPS Hospice Survey vendor? A hospice agency is not permitted to administer its own CAHPS Hospice Surveys. Instead, every hospice agency is required to contract with an approved CAHPS Hospice Survey vendor. The vendor will administer the CAHPS Hospice Survey on an
November 7, 2022 · 3 min read
How to recruit and retain hospice volunteers
What is a hospice volunteer? Hospice volunteers are key contributors to a hospice agency. The hospice movement was started with volunteers and there are now more than 460,000 volunteers nationwide. To retain the initial spirit of hospice, Medicare requires that volunteers must provide se
October 21, 2022 · 2 min read
Calculating the volunteer cost savings match
What are hospice volunteers? The hospice movement was started by volunteers and there are currently more than 460,000 hospice volunteers nationwide. To retain the volunteer-based essence of hospice, one of the Medicare conditions of participation requires that hospices incorporate volunteer services
October 20, 2022 · 2 min read
What is a hospice's volunteer requirement?
Volunteers are an essential components of hospice. The hospice movement was started by volunteers. There are currently more than 460,000 hospice volunteers nationwide. Volunteers provide administrative support or direct patient care services. Are hospices required to have volunteers? Use of voluntee
October 20, 2022 · 4 min read
Tips for avoiding hospice election form denials
What is a hospice election statement? A hospice election statement is a condition of payment under Medicare. For a patient to be eligible to receive hospice services under the Medicare benefit, the patient or the patient's authorized representative must elect hospice care by signing a hospice electi
October 18, 2022 · 3 min read
What is the Hospice Election Statement requirement?
To receive hospice services under the Medicare benefit, a patient or his authorized representative must elect hospice care. If the patient or authorized representative elects to receive hospice care, the patient must file an election statement with a specific hospice agency. The election statement s
October 18, 2022 · 3 min read
Medicare Credit Balance Report
What is Medicare credit balance? A Medicare credit balance represents a Medicare overpayment to a provider due to patient billing error or claims processing error that must be refunded to Medicare. The report is referred to as a Credit Balance Report because when a provider receives excess payment
September 29, 2022 · 3 min read
Untimely NOE: Requesting an Exception
September 20, 2022 · 1 min read
Hospice Acronym Alphabet Soup
Are you confused by the Acronym Alphabet Soup? Does the never ending list of acronyms used in the hospice and healthcare industry leave you confused? Are you worried that you may confuse CMN with CMP? To help sort out the confusion, we add here links to lists of acronyms: Acronyms commonly found on
September 15, 2022 · 1 min read
Timely filing of Notice of Election
The Notice of Election (NOE) is more than a clinical administrative task; it is a critical financial trigger. In the hospice revenue cycle, the NOE serves as the formal notification to Medicare that an agency has assumed responsibility for a patient’s care. Failure to file this document within the m
September 12, 2022 · 2 min read
What is a MAC?
A Medicare Administrative Contractor (MAC) is a private health care insurer that has been awarded a geographic jurisdiction to process Medicare Part A and Part B medical claims for Fee For Service (FFS) beneficiaries. CMS relies on these contractors to serve as the primary operational contact betwee
September 12, 2022 · 2 min read
How to Submit a Notice of Election (NOE)
What is a Notice of Election? When a Medicare beneficiary elects hospice services, the hospice must complete an election notice with the beneficiary and file a Notice of Election (NOE) with Medicare. A Notice of Election (NOE) is the formal mechanism used to notify Medicare that a beneficiary has e
September 8, 2022 · 2 min read
Unusual Circumstances: Face to Face Encounters
Prior to the third hospice benefit period, and prior to each subsequent benefit period, a hospice physician or nurse practitioner is required to have a face to face encounter with the hospice patient to recertify that the patient continues to be Medicare eligible for hospice benefits. The face to f
August 4, 2022 · 2 min read
What is Face to Face Recertification?
A hospice face to face encounter is a step in patient recertification beginning with the third benefit period and each benefit period thereafter. The goal of hospice face to face patient encounter is to encourage greater involvement of the physician in the care of patients who have been on hospice f
August 4, 2022 · 3 min read
Core Services: Using Employees versus Contractors
Hospice Conditions of Participation – employees versus contractors Hospice conditions of participation require that almost all hospice core services are delivered by hospice agency employees and may not be delivered by contractors. Hospice core services include: Nursing services Social services Coun
August 1, 2022 · 1 min read
Navigating the Hospice Initial Accreditation Process
What is hospice initial accreditation and why is it important? Hospice initial accreditation is a way to ensure delivery of consistent and high quality services across all accredited hospice agencies. The accreditation program ensures that the hospice agency is fully compliant with Medicare Conditio
July 31, 2022 · 5 min read
Do you have a reportable data breach?
Concerned that you have a data breach? Not everything that looks like a data breach is, in fact, a reportable data breach. Before you report a data disclosure to the US Department of Health and Human Services Office for Civil Rights (OCR), you should confirm that what you are concerned is a re
July 31, 2022 · 4 min read
