Home Health & Hospice Week

Medicaid PCS also tops to-do list.

If the HHS Office of Inspector General’s Work Plan for 2017 is any indication, home health agencies are in for more scrutiny in the new year. And that means you’d better audit the risk areas highlighted in the plan — before the feds do.

The OIG outlines three topics it plans to tackle next year:

1. “Comparing HHA Survey Documents to Medicare Claims Data.” This newly announced report, expected in 2018, will examine whether HHAs supply accurate patient information (i.e., rosters and schedules) to state surveyors. “State agencies do not have access to Medicare claims data to verify this information,” the OIG notes in its blueprint document. “Therefore, fraudulent HHAs might intentionally omit certain patients from information supplied to State agencies to avoid scrutiny. Previous OIG work has shown that the home health program is prone to fraud, waste, and abuse.”

2. “Home Health Compliance with Medicare Requirements.” This report expected in 2017 notes the often-cited Medicare payment error rate for HHAs (51 percent in 2014). “We will review compliance with various aspects of the home health prospective payment system and include medical review of the documentation required in support of the claims paid by Medicare,” says the OIG, which also specifically mentions homebound and skilled service criteria.

3. “Data Brief on Fraud in Medicaid Personal Care Services.” The OIG will issue more information on this hot button fraud area. The info will include “State and Federal investigations, indictments, convictions, and recoveries involving fraud and patient abuse or neglect in Medicaid PCS,” according to the Work Plan. “The data presented in this brief are intended to illustrate the prevalence and magnitude of fraud and patient abuse or neglect involving PCS. These data will be especially important for OIG’s future work with CMS to combat these issues.”

Review: The OIG also highlights its report issued this past June, “Nationwide Analysis of Common Characteristics in OIG Home Health Fraud Cases” (see Eli’s HCW, Vol. XXV, No. 24). The report listed five common factors in HHA fraud cases (see sidebar, this page).

Take Action: Don’t just read the Work Plan and forget about it, urges law firm Hall Render in its summary of the plan. “Providers should familiarize themselves with the Work Plan and use it to help identify potential risk areas in their organizations,” the firm advises. “The Work Plan is a critical tool in maintaining an effective compliance program and may help prevent government scrutiny and enforcement activity at your organization.”

Note: The Work Plan is at http://go.usa.gov/xkSmH.