Home Health & Hospice Week

2006 Work Plan also focuses on Home Health Compare.

If you think the heat has been on home health therapy this year, the feds are getting ready to turn it up even hotter.

The HHS Office of Inspector General "will determine whether home health agencies' therapy services met the threshold for higher payments in compliance with Medicare regulations," its recently released work plan for 2006 says. The OIG "will analyze the number and the duration of therapy visits provided per episode period," the agency adds.

Home health agencies soon will see the cash flow impact of the M0175 errors that drew attention from OIG in 2001. And OIG-instigated audits of claims with 10 or more therapy visits have resulted in high percentages of denials and significant overpayments for three agencies in 2005.

Now, the recently-released 2006 OIG Work Plan promises a continuing effort to plug perceived cash leaks--at your expense.

Tip: With the extra $2,000 in reimbursement Medicare pays for episodes that include 10 or more therapy visits, these high-therapy claims are a tempting target for the feds. Agencies that have not yet scrutinized their high-therapy claims for weaknesses should do so, experts warn. That's especially true for claims where the denial of only one or two visits can cost you several thousand dollars.

Focus on complying with the Medicare regulations such as dating and signing doctors' orders and thoroughly documenting the medical necessity of visits, the patient's homebound status and detailed descriptions of the therapy provided, advises Cindy Krafft, director of rehabilitation services for OSF Home Care based in Peoria, IL.

Other home health issues in the work plan include: 

• Home health outlier payments. The OIG will continue its ongoing investigation into whether outlier payments are equitable to all HHAs and whether they cluster in certain home health resource groups or geographic areas, according to the work plan. • Survey and certification. A new project in the work plan aims to determine if any HHAs show "patterns of cyclical noncompliance with certification standards." The OIG also will analyze HHA survey deficiency trends and patterns, the work plan says. • Home Health Compare. Another new project plans to determine the accuracy and completeness of the information about Medicare-certified agencies that the Centers for Medicare & Medicaid Services provides on the Home Health Compare Web site. The site compares HHAs' patient outcomes.

Note: The OIG Work Plan is online at www.oig.hhs.gov/publications/workplan.html.