The Office of Inspector General (OIG) recently released the OIG Work Plan for 2014, which outlines the primary objectives of each quality of care, compliance and fraud reduction projects. Home Health and Hospice providers must adhere to a set of standards unique to the continuing care industry, and many are not in compliance. OIG has made it clear what these organizations need to align to avoid fraud or abuse.
As part of this year's Work Plan, Home Health agencies will be reviewed for compliance with the prospective payment system (PPS) including required documentation supporting the claim paid by Medicare and beneficiary meeting the required home bound status. High emphasis will be placed on newly enrolled home health care agencies based on a surge of instances of heightened fraud, waste, and abuse, particularly in certain geographic regions of the country.
Hospice agencies will be reviewed for appropriateness of hospice services provided in both inpatient care and in assisted living facilities. The OIG will determine the length of stay, levels of care received and common terminal illnesses of beneficiaries who receive hospice care in assisted living facilities. Furthermore, the content of the notice of election (NOE) statements will be reviewed for hospice beneficiaries who received care. The OIG will review hospice medical records to address concerns that the level of care is appropriate and is not being misused.
A few simple steps can help ensure your agency is compliant:
Explain clearly on the face-to-face encounter documentation why the findings from the encounter support the medical necessity of the services ordered and the beneficiary's homebound status.
Meet the required condition for payment on the face-to-face encounter within 90 days prior to the start of care or up to 30 days after the start of care. For more information, refer toMLN Matters Special Edition Article #SE1405.
Perform your own internal audit and review of beneficiaries on service to assess your agency's compliance.
Perform an internal audit and review of beneficiaries on service to assess your agency's compliance. Focus on the comparison of medical records documentation against the claims billed.
Review your agency's notice of election (NOE) procedures and content requirements.
The key to your agency being compliant is educating your referral sources of face-to-face requirements and consistent documentation. Equally important is identifying your agency's areas of improvement and initiating a process improvement plan.
Continued scrutiny by the OIG and other federal oversight programs is a certainty. The key to agency success in any compliance initiative is based on a focused approach toward education of referral sources, physicians and staff. Adherence to best practices for both "face to face" requirements and documentation of medical necessity as well as services provided will be a strong foundation for an agency "Compliance Toolkit."
Discuss: What issues has your HHA Agency faced in regards to billing compliance?