Two recent OIG reports examine Medicare policies involving hospice services. The first report concentrates on hospice general inpatient care (GIP), under which short-term pain control or symptom management that cannot be managed in other settings is provided in an inpatient facility (a Medicare-certified hospice inpatient unit, a hospital, or a SNF). Medicare paid $1.1 billion for GIP in 2011, mainly for care in hospice inpatient units. Almost one-quarter of hospice beneficiaries received GIP that year, with one-third of the stays exceeding 5 days. On the other hand, 27% of Medicare hospices did not provide any GIP, and many of these hospices did not provide any level of hospice care other than routine home care. The OIG believes additional review is needed to ensure that hospices are using GIP as intended and providing the appropriate level of care. The OIG also suggests that CMS ensure that hospices that do not provide GIP are offering the necessary levels of care, such as through adoption of a quality measure regarding hospices’ ability to provide all hospice services.
The second report examined the growth in Medicare beneficiaries’ discharges from acute-care hospitals to hospice care, and its impact on hospital payment. While Medicare has “transfer payment policies” that adjust payments to hospitals for early discharges (i.e., sooner than a Medicare-established average length of stay) to other hospitals or postacute-care facilities, Medicare does not currently have a transfer payment policy for early discharges to hospice care. The OIG estimates that Medicare could have saved more than $602 million in 2009 and 2010 by applying a hospital transfer payment policy for early discharges to hospice care. The OIG recommends that CMS adopt regulations or pursue a legislative change, if necessary, to establish a hospital transfer payment policy for early discharges to hospice care. CMS will study the recommendations.