The lines of communication between hospice leaders and compliance executives need to be open and transparent in today’s regulatory environment.
The complexities of hospice regulation alongside increased oversight in the space have led providers to zero in on compliance. A host of new audit activity has cropped up in recent years, as well as ramped up scrutiny around quality and program integrity.
The ability to both understand and navigate shifts in regulations requires a solid relationship between a hospice executive team and its compliance leaders, according to Avow Hospice President and CEO Jaysen Roa.
To achieve this, compliance and senior executive teams should foster interlocking collaboration and careful communication, he stated in a recent Husch Blackwell podcast.
“It’s having compliance be part of the fabric,” Roa said. “Whether it is redoing some policies and procedures, looking at our code of ethics or how we respond to audits … it’s all these things that can be esoteric to us [leaders]. When speaking to peers, whether it’s the C-suite, leadership teams or the board, [it’s doing] it in a way where it’s relatable and they understand not only why it’s important, but also the impact of why we’re readying for this. [If] we’re not constantly learning, then that’s a problem — especially in an industry like ours where it’s dynamic and changing every single day.”
Avow Hospice provides pediatric and adult palliative and hospice care across Southwest Florida. Established in 1983, The nonprofit hospice is part of a multi-facility health care system and a member of the Mayo Clinic Care Network. The system includes two hospitals with a total of 713 beds and dozens of other medical facilities throughout Florida.
The hospice organization in 2015 began considering a “retooling” of its C-suite structure in preparation of rising regulatory oversight, Roa said.
That year, Roa took the helm at Avow Hospice, overseeing the growth of its palliative and hospice programs, along with its pediatric grief and veterans programs. Prior to joining the organization he served as executive director at Good Shepherd Hospice.
“We were thinking about what our C-suite looked like in terms of the different structures and downlines and ultimately trying to prepare for the next five, 10, 15 years and knowing that there were these monumental changes coming,” Roa said. “[It] was thinking about the future and understanding what was going to happen with all these government audits, quasi government audits and all of these different functions. With the times changing, we knew that we needed to be prepared for all of that to continue to be a compliant organization.”
Part of the organization’s restructuring included a close look at how executive and compliance teams collaborate, Roa said. Since his ascension, Avow Hospice has hired a new chief compliance officer and senior vice president of engagement, Kerri Ervin.
Ervin joined Avow Hospice in 2003, working in various clinical and non-clinical roles. She was most recently its corporate compliance officer, previously serving as both an admission and a triage nurse, long-term care manager, quality improvement specialist and senior director of quality, among other roles.
Strong ties between compliance and executive teams are crucial, according to Ervin. Having honest and transparent communication between compliance officers and hospice executives is key, she said.
“From a compliance officer perspective, and for anyone in leadership, but a compliance is changing so quickly with the regulations and everything happening, that if you aren’t a learner and you aren’t staying on what’s happening in your field and understanding it, then you’re going to have a hard time keeping up for yourself and for your organization,” Ervin said during the podcast.
This year has brought several regulatory changes to the hospice space, including the proliferation of various audits, including Targeted Probe and Educate (TPE) audits conducted by Medicare Administrative Contractors (MACS). Other types involve Unified Program Integrity Contractors (UPIC), Supplemental Medical Review Contractors (SMRC) and Recovery Audit Contractors (RAC).
Next year will bring the establishment of the Special Focus Program (SFP). The U.S. Centers for Medicare & Medicaid Services (CMS) launched the SFP program in its final 2024 home health rule.
Also in 2024, higher penalties for hospices who do not submit data to the Hospice Quality Reporting Program (HQRP) will take effect. Providers now face a 4% payment reduction for failure to submit data, up from 2% that CMS stipulated 2024 hospice final payment rule.
Maneuvering through a sea of regulatory changes can be turbulent at times, according to Ervin. Education is key to ensuring compliance, along with fostering an organizational culture of approachability and information sharing, she stated.
“[It’s] making it a point of promoting education [and] that’s been a key in my development,” Ervin said. “A key to success in the role is developing relationships with other people so you can learn from them. [It’s] wanting to grow and develop in the compliance world, because of all of the areas we work in. The support of this organization has been key to be able to do that.”
Companies featured in this article:
