Please
be assured my intention was not to cast aspersions on anyone. Rather it was to
question the necessity of the decision to shut down the very highly regarded
San Diego Hospice and Institute for Palliative Medicine in the wake of a
Medicare Post-Payment Review of 149 patients.
What
you call a 15 year long cultural disregard for the compliance requirements
of Medicare mischaracterizes the Open Access policy pioneered by HSDIPM and
now employed by more than one in four hospices throughout the country. Medicare
eligibility rules clearly do not allow hospices to serve patients who seek curative
care, and both the hospice physician as well as the patients’ physician must
certify (and periodically re-certify) that the patient is terminal with a
prognosis of less than 6 months to live. Within this framework however hospices
are permitted to establish their own policies, procedures and criteria for
admission and discharge. Whether a patient has a willing and able caregiver
available at home can affect whether a hospice accepts or declines to serve a
patient who meets all Medicare Hospice eligibility requirements. Abundant
research has examined restrictive enrollment policies as barriers to hospice
care. (The Debate in Hospice Care, J Oncol Prac, May 1, 2008: 153-157 http://jop.ascopubs.org/content/4/3/153.full).
It appears to me SDHIPM's efforts to maintain an Open Access policy is
commendable. You ascribe the fate of this organization to a new CEOs
attempt to change the culture, purge the executive team, but it was too
late…for what? Too late to manage to achieve proper alignment between a
commitment to provide the best possible hospice care and Medicare regulatory
compliance, an intention the executive expressed in a Nov 13 press report.
I
am familiar with the financials, as reported to the CA Office of Statewide
Health and Development (and available to anyone with an internet connection).
In 2011 this hospice, with an annual unduplicated census of 4,665 patients
spent $320K in palliative radiation therapy alone. In total for 2011, net
operating expenses of $81M exceeded net patient revenue of $71M. Non-operating
revenue including community support such as “donations and contributions”
amounted to $12.5M, producing a positive total fund balance.
Another
interesting item included in this report is the 78,375 “Medicare Reportable
Hours of Volunteer Services”. While this may be of little relevance to the
bankruptcy court, it is, and I hope you would agree, a genuine asset, and
perhaps one more small reason to hope that those involved in the governance of
this voluntary non-profit organization would muster the devotion to emerge from
Chapter 11, rather than permanently abandon operations and put an end to the
mission on which the organization was built.
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