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Make sure you're ensuring accuracy & compliance
by Isaac Smith

Hospice care offers support for patients in the final stages of terminal illnesses. Like all health care services, maintaining proper billing compliance is crucial for hospices to meet federal and state regulatory standards. These regulations aim to prevent fraud, ensure the appropriate use of funds and guarantee that patients receive necessary care. 

This article explores the complexities of hospice billing compliance, the significance of following regulations and some steps hospices can take to remain compliant.

Understanding the Basics Behind Hospice Billing Compliance

Hospice billing compliance involves following the guidelines and regulations set by the Centers for Medicare & Medicaid (CMS) and private insurance companies. These rules are essential to ensuring accurate billing and payment for hospice services. 

The Medicare Hospice Benefit is a crucial aspect that provides coverage for terminally ill patients. CMS requires hospices to adhere to certain billing codes and documentation standards to receive payment.

Compliance includes understanding the Hospice Item Set (HIS) and its data reporting requirements. The HIS is a standardized tool that hospices must complete for every patient to ensure proper care delivery and compliance with quality reporting mandates. Inaccurate completion or failure to submit the Hospice Item Set can lead to penalties and reduced payments for an organization.

Hospices must remain current on updates to billing codes and regulations. CMS frequently revises billing guidelines, making it essential for hospices to keep their staff informed through continuous education to meet the latest requirements.

Common Compliance Issues in Hospice Billing 

There are three main challenges that providers face in hospice billing:

Improper Documentation: One of the most frequent challenges in hospice billing compliance is improper documentation. Accurate and comprehensive documentation is crucial to proving that the services provided are medically necessary and comply with regulatory standards. Hospices must ensure that patient records are complete, including essential details like physician certifications of terminal illness, care plans and progress notes.

Non-Covered Services: Another major compliance issue is billing for non-covered services. Hospices need to be aware of what services the Medicare Hospice Benefit covers and what it does not. For instance, services aimed at curing terminal illness are typically not covered. Billing for these services can result in audits, demands for repayment and potential legal troubles.

Coding and Billing Errors: Improper coding and billing mistakes can compromise compliance. Hospices must use accurate codes for the services rendered and ensure that all claims are submitted correctly. Coding errors can lead to payment delays, denials and possible penalties. Regular audits and reviews of billing practices can help identify and rectify these issues before they escalate.

Strategies to Ensure Compliance

Here are eight strategies providers can adopt to ensure their hospice billing process is compliant.

1. Invest in education & training.

Hospices should consider investing in certification programs for their billing and coding staff. Certifications like the Certified Hospice and Palliative Care Administrator (CHPCA) or the Certified Hospice and Palliative Nurse (CHPN) offer advanced training and can help ensure that staff are fully prepared 
to manage the complexities that come with hospice billing.

2. Implement comprehensive electronic medical records.

Utilizing electronic medical records (EMRs) ensures vital information is readily accessible to your staff. These systems not only enhance information accessibility but also support timely and accurate data entry and team collaboration.

3. Ensure timely updates.

Avoid delays in patient care documentation by setting clear expectations for prompt updates in an easy-to-use electronic system. Quick integration of new information into the records enhances the care team’s ability to collaborate effectively and provide superior care.

4. Train staff on documentation best practices.

Beyond using convenient tools and establishing clear expectations, dedicating time to train staff on best documentation practices is crucial. This helps them integrate these processes easily into their routines. Regular training sessions to review software tools and your organization’s specific standards can improve their understanding.

5. Integrate quality checks.

Conduct quality checks to ensure documentation accuracy and adherence to best practices. These checks are essential for assessing compliance with established standards and improving overall effectiveness.

6. Utilize technology for efficiency.

Once staff are adept with the technology, they can streamline documentation processes within the electronic medical records system. Evaluate which features of your system can minimize documentation time, reduce redundancies and eliminate inefficiencies.

7. Personalize patient care plans.

Customize care plans to address individual treatment and comfort needs. Storing these plans in a centralized location accessible to all team members facilitates updates and ensures continuity of care.

8. Conduct regular audits.

Routine audits and reviews of billing practices help catch compliance issues early. These audits should examine patient records, billing codes and claim submissions for accuracy and completeness. Using third-party experts for external audits adds extra oversight. This helps pinpoint areas for improvement and ensures thorough compliance.

Ensuring compliance with hospice billing regulations is crucial for delivering high-quality care. By understanding the requirements, addressing common issues and implementing strong controls, hospices can meet all relevant regulations and get accurate compensation for their services.

Keys to Hospice Compliance:
  • Follow guidelines from Medicare, Medicaid and private insurers.

  • Ensure proper documentation, understand covered services and use accurate coding.

  • Conduct regular audits, implement strong internal controls and use technology for accurate billing.

  • Provide ongoing education and training to keep staff updated on billing regulation changes.



Isaac Smith is an accomplished health care professional with more than 13 years of experience in health care administration, medical billing, and coding and compliance. He holds several AAPC specialty certifications and has a bachelor’s degree in health administration. He currently works for Medcare MSO, a New Mexico-based medical billing services provider for hospice, cardiology and more, in the ICD-10 editorial department. Visit medcaremso.com.