The IMPACT Act of 2014 (“IMPACT”) was signed into law on October 6, 2014. It includes two significant enforcement and oversight changes for Medicare hospice providers among other post-acute care policy changes.

IMPACT increases the frequency of survey and certification inspections for hospice providers. It mandates that hospices undergo a certification inspection no less frequently than once every 36 months. Previously, the frequency of inspections was left up to the State Agencies performing the inspections.

IMPACT requires medical review of hospice programs with a high percentage of patients who receive care for 180 days or more. CMS is required to set a threshold percentage or number of patients receiving care for more than 180 days that will trigger medical review.

The increased frequency of certification inspections and the focus on long-stay patients are intended to address long standing concerns, voiced by the OIG in several reports, that hospices were not receiving sufficient oversight and that there were too many abuses of the hospice benefit by providers who were servicing patients with questionable diagnoses or certifications of terminal illness.