Frequency of Medicare Recertification Surveys for Hospices Is Unimproved

WHY WE DID THIS STUDY

This memorandum report follows up on the 2007 OIG report Medicare Hospices: Certification and Centers for Medicare & Medicaid Services Oversight (OEI-06-05-00260), which found that the most recent recertification survey for 14 percent of State-surveyed hospices had occurred more than 6 years previously, with an average of 9 years. Further, when surveys did occur, 46 percent of the surveyed hospices received citations for health deficiencies, with the most frequently cited deficiencies related to care planning and quality issues. We recommended that CMS seek statutory or regulatory timeframes for the frequency of hospice recertification surveys by State survey agencies, and suggested a timeframe of 3 years. CMS did not concur with the recommendation, indicating that conducting more frequent surveys would require congressional action to allocate additional resources. CMS policy sets targets for the frequency of hospice recertification surveys by State survey agencies. These targets vary over time based on available resources and priorities.

HOW WE DID THIS STUDY

We analyzed national survey data for all hospices that had Medicare payments in 2011 and that were subject to surveys by State survey agencies on behalf of CMS, a total of 2,483 hospices. We determined the certification survey frequency for each State-surveyed hospice by calculating the time between the date of the most recent certification survey (either initial certification or recertification) and the index date, February 28, 2013. We determined the proportion of hospices that had not been surveyed within the 6 years preceding the index date, both nationally and by State, and compared those results to our prior findings.

WHAT WE FOUND

We found that the frequency of recertification surveys has not improved since 2005. Seventeen percent of State-surveyed hospices had not been recertified within the 6 years prior to the index date of February 28, 2013, with some hospices experiencing longer intervals since their last survey. We also found that in 12 States, more than 25 percent of hospices had not been recertified within the previous 6 years. These findings illustrate that CMS's use of fluctuating annual targets does not ensure timely recertification surveys of all hospices and raises concerns about whether CMS and contracted State survey agencies can ensure hospice compliance with Medicare CoPs and quality-of-care requirements for hospices.

Therefore, we reiterate the recommendation that CMS seek statutory or regulatory timeframes for the frequency of hospice recertification surveys. CMS could consider setting this survey frequency standard at 3 years, to match the 3-year interval used by accrediting organizations (as approved by CMS); however, given resource limitations, setting a mandatory frequency-even for an interval of more than 3 years-could help to ensure improvement in survey frequency and avoid lengthy intervals between surveys for individual hospices.