Looking at Hospice Relatedness Determinations through the Legal Lens: Substantiating Your Decisions to Stand Up to Government Scrutiny

Friday, March 28, 2014: 11:00 AM-12:00 PM
National Harbor 12-13 (Gaylord National Resort and Convention Center)
Primary Presenter:
Mary H. Michal, JD
Co-Presenter:
Katherine A. Proctor, JD
Area of Emphasis: Regulatory Issues
Learning Objectives:
1. Learn the legal framework for relatedness determinations
2. Understand considerations for substantiating a relatedness determination
3. Explore the implications of past and present guidance and government enforcement
The regulatory arena for hospice is constantly evolving making it difficult for hospices to stay ahead of the curve.  While determinations as to whether a condition or symptom is "related to" the terminal illness is not a new challenge, hospices are beginning to see the implications of such decisions through pharmacy audits and increased government scrutiny.  The presenters will share their breadth of knowledge of past and present relatedness determinations, recent government investigations on the issue, and discuss key considerations to help hospices substantiate and support such determinations.  Attendees will also learn about the legal framework for relatedness determinations, including the standard and burden of proof that hospices would want to meet in order to defend challenges to determinations.
Handouts
  • MLC14_6C_The Non-Clinical Side of Hospice Relatedness Determinations.pdf (125.3 kB)
  • MLC14_6C_2013.12.6 CMS Memo to Part D Plan Sponsors and Hospices (Kate markup).pdf (1.2 MB)
  • MLC14_6C_2014.3.10 CMS Memo to Part D Plan Sponsors and Hospice re Pre-Authorization.pdf (254.8 kB)
  • See more of: 90-minute Session