Hospice Model Compliance Plan / Using OIG's hospice model compliance program / Risk Areas

Why This Topic Matters

Hospice organizations need compliance programs that address major operational, billing, eligibility, and referral risks. Understanding the scope of OIG-flagged concerns helps providers strengthen internal controls and reduce exposure to regulatory and payment problems.

Article Sections

1. Policy and procedure development

   Introduces the role of written policies and procedures in hospice compliance programs and their relationship to training and internal oversight. Discusses use of management input and OIG-identified concerns as part of risk assessment.

2. OIG hospice risk areas

   Presents a broad inventory of compliance risk areas identified for hospices. The section spans eligibility, reimbursement, documentation, referrals, staffing, marketing, subcontracting, volunteers, and related program integrity topics.

3. Additional risk assessment considerations

   Addresses the need to revisit prior compliance problems and incorporate any further risk areas into hospice policies, procedures, and training. Emphasizes ongoing assessment as part of an effective compliance program.