Hospice Medicare & Medicaid Audits

The Hospice Audit team’s expertise extends to every issue that arises in audits, including complex medical review, documentation requirements, and applicable legal and medical standards. 

• Audit insights: The Hospice Audit team’s extensive work on audits of all kinds allows us to answer your questions regarding who is auditing, how they audit, typical audit results and how to preempt or appeal them, current trends in hospice audits, and how to develop a bespoke optimal strategy.
• Hospice knowledge: The Hospice Audit team works with hundreds of hospices every year and knows how hospices work. The Hospice Audit team leverages its extensive experience with the business of hospices, complex medical conditions, the intricacies of necessary documentation, and the web of laws and regulations to “speak the same language” as hospice leadership, physicians, clinical staff, billing personnel, and others to mount the strongest audit defense possible. 
• Extrapolation audits: The Hospice Audit team also regularly represents hospices in the face of financially crippling “extrapolated” audits, in which the denial of a relatively modest number of claims is statistically extrapolated to result in millions or tens of millions of dollars in overpayments. The Hospice Audit team has eliminated over 90 percent of the extrapolated audits it has challenged, saving hospices nearly $200 million.
• Alternative dispute resolution (ADR): The Hospice Audit team is well-versed in assessing settlement opportunities that meet the hospice’s objectives. The Hospice Audit team has worked to achieve successful partial and full settlements and resolutions through the following: 
  • Qualified Independent Contractor (QIC) Telephone Demonstration Project
  • Office of Medicare Hearings and Appeals (OMHA) Settlement Facilitation Conference (SCF)
  • Medicare Administrative Contractor (MAC) Extended Repayment Schedule (ERS) Process
  • Centers for Medicare & Medicaid Services (CMS) Division of Debt Resolution
  • Department of Health and Human Services (DHHS) Office of Inspector General (OIG)
  • Department of Justice (DOJ)

The alphabet soup of Medicare audits has expanded over the years, and the Hospice Audit team has seen them all. Unified Program Integrity Contractor (UPIC), Supplemental Medical Review Contractor (SMRC), Center for Program Integrity (CPI), Targeted Probe and Educate (TPE), and Medicare Administrative Contractors (MAC) medical reviews demand a thoughtful and forceful response from hospices. The Hospice Audit team has fought for hospices each step of the way, from the initial record request through the entire appeal process.

Medicaid audits involve a unique combination of federal and state authorities and processes. The Hospice Audit team has stood up to federal Medicaid auditors and fought for hospices across the country in a variety of distinct state venues, from the initial record request through the entire state appeal process.

See our hospice Medicaid advocacy in action.

Among the most daunting of audits are those performed by the federal DHHS Office of Inspector General (OIG), for two reasons:

• First, the OIG’s standard practice is to extrapolate its audit results, regularly leading to alleged overpayment amounts of millions or tens of millions of dollars. 
• Second, unlike other audits, the OIG publishes its audit results on its website, for the public to see. 

The Hospice Audit team represents hospices in OIG audits, applying its audit experience and guiding a public relations strategy designed to address the unique feature and risks relating to these audits.