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Here are some of the special areas of OIG concern included in the draft compliance program for hospice:
• Uninformed consent to elect the Medicare hospice benefit.
• Discriminatory admission.
• Admitting patients to hospice who are not terminally ill.
• Arrangements with other providers that a hospice knows is submitting claims for services already covered by the Medicare benefit.
• Falsified medical records or plans of care.
• Untimely and/or forged physician certifications on plans of care.
• Inadequate or incomplete services rendered by the interdisciplinary group.
• Hospice incentives to actual or potential referral sources, such as physicians, nursing homes, hospitals, etc.
• Overlap in services that a nursing home provides which result in insufficient care provided by a hospice to a nursing home resident.
• Improper relinquishment of core services and professional management responsibilities to nursing homes, volunteers, and privately paid professionals.
• Providing hospice services in a nursing home before a written agreement has been finalized.
• Billing for higher level of services than necessary.
• Inadequate justification in the medical record when a patient revokes the Medicare hospice benefit.
• Billing for hospice care provided by unqualified or unlicensed clinical personnel.
• False dating of amendments to medical records.
• High pressure marketing of hospice care to ineligible beneficiaries.
• Improper solicitation activities, such as "patient charting."
• Inadequate management and oversight of subcontracted services, which result in improper billing.
• Sales commissions based on length of stay.