Ensuring Compliance with General Inpatient (GIP) Care

Hospice providers continue to be under high scrutiny for their use of General Inpatient (GIP) care.  As audits increase, strict compliance is essential to avoid financial penalties and ensure quality patient care.

The Heightened Regulatory Landscape

A 2016 Office of Inspector General (OIG) study found that 31% of GIP claims were billed inappropriately, leading to $268 million in improper payments.  This triggered stronger oversight from the Centers for Medicare & Medicaid Services (CMS) with the OIG recommending:

• More medical reviews, especially for GIP stays in skilled nursing facilities (SNFs) and for-profit hospices.
• Prepayment scrutiny of stays longer than seven days.
• Stricter physician involvement requirements for GIP initiation and continuation.
• Enhanced surveyor efforts to verify compliance with care planning regulations.
• New enforcement actions, such as financial penalties and mandatory training.

By 2023, more than half of hospices nationwide were undergoing multiple audits ranging from Targeted Probe and Education (TPE) to Recovery Audit Contractors (RAC) and Unified Program Integrity Contractors (UPIC).  GIP stays over five days are a particular focus, and the OIG is also reviewing compliance with the inpatient payment cap, requiring hospices exceeding the 20% inpatient threshold to return excess Medicare funds.

Ensuring GIP Compliance

To remain compliant, hospices must fully understand GIP’s purpose: managing acute symptoms that cannot be controlled in a home setting.  GIP must be provided in an approved facility, such as a hospital, SNF, or hospice inpatient unit.  It cannot be used simply because a patient is actively dying or a caregiver needs respite.

Key compliance requirements include:

• 24-hour nursing care, distinct from routine facility services.
• Hospice-managed patient care, ensuring continuous oversight.
• Daily documentation justifying the need for GIP services based on medical necessity.

The Role of Documentation

Incomplete or vague documentation is the leading cause of audit failures and claim denials. To avoid this, providers should:

• Clearly document the medical need for GIP every day.
• Track symptom changes, interventions, and care plan updates.
• Ensure interdisciplinary team consistency, creating a complete, defensible record.

Proactive Strategies for Compliance

To reduce risk and enhance readiness, hospices should adopt proactive compliance measures:

1. Internal Audits & Risk Assessments – Regularly review practices against CMS requirements.
2. Staff Training & Education – Ensure teams understand GIP criteria and documentation standards.
3. Mock Surveys – Conduct internal audits mirroring CMS protocols.
4. Supervisory Accountability – Implement concurrent chart reviews to catch errors in real time.
5. Ongoing Documentation Audits – Identify and correct gaps before an external review.

With GIP utilization under intense regulatory focus, hospice providers must stay ahead of audits through diligent compliance, robust documentation, and proactive oversight.  These steps not only safeguard financial stability but also uphold the highest standard of end-of-life care.