On September 1, 2023, Ari Markenson was featured in a Q&A in Hospice News regarding the U.S. Centers for Medicare & Medicaid Services’ (CMS) new rules for changes in hospice ownership policies. Here is an excerpt:
Q. There’s a lot of conversation about the payment update with a lot of providers saying that it’s inadequate. But what are some of the aspects of the rule that people aren’t talking about as much that should be getting more attention?
A. The focus that they’ve put now on their concerns about hospice program integrity and adding the hospice providers to what’s called the 36-month rule, changing how their survey and certification process is going to work — those issues are pretty significant.
The 36-month rule, when it was implemented for home health really had a significant impact on a very specific type of potential program integrity issue in home health. Home health has been and still is a very easy health care provider type for entrepreneurs to sort of enter the marketplace. And as a result, it also became a place for less than scrupulous folks to join the marketplace.
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