Home Health & Hospice Week

Invest resources on the front end of RAC review, so the back end doesn't close your doors.

With so much riding on your documentation supporting claims - possibly even your agency's survival - in the current RAC and TPE environment, make sure your claims are ready to withstand some stiff scrutiny.

"The only thing home health providers can do is pray for the best and prepare for the worst," says consultant Pam Warmack with Clinic Connections in Ruston, Louisiana. "We have no control over the topics selected by the Centers for Medicare & Medicaid Services for review, but we can prepare ourselves to face a review."

Warmack urges agencies to invest in their Quality Assurance programs, which will also help with their compliance with the new Home Health Conditions of Participation. "The key to a successful provider is a quality assurance program. QA should be comprehensive enough to ensure a provider can withstand any type of scrutiny," Warmack tells Eli.

A quality QA program will address risk areas that most threaten your reimbursement - both on the agency and industry levels. "Through internal review, we should constantly be searching for weaknesses in our processes and documentation and working to strengthen them," Warmack advises.

Remember: Recovery Audit Contractor Performant's selection of agencies for audit is not arbitrary, stresses Judy Adams with Adams Home Care Consulting in Durham, North Carolina. Instead, it is "based on data mining to identify agencies that are markedly different than their peers, plus information on agency past claims," Adams explains. "It is not random selection."

Key: "Constant clinical education is the starting point" for improving your documentation, Warmack urges.

Don't fall into the trap of thinking you don't have the time or resources for a QA effort. "I am often told, by owners, that they simply can't afford a quality assurance program. Even with the new Conditions of Participation QAPI regulations, there are owners who seek to circumvent the requirement," Warmack relates.

That thinking can be dangerous. "Eventually you will pay, one way or the other," Warmack cautions. "Pay for quality to begin with, or lose your business later down the line."

Do this: When faced with an ADR, "review all the documentation in detail," Warmack exhorts. "Prepare a written summary to accompany the documentation. Collect as much supplemental documentation from physicians, ER visits, hospitalizations, wound clinics, etc. to submit with the agency's documentation."

And you'll likely fare better if you get some outside help with doing that documentation review and prep, agree Warmack and Tom Boyd with Simione Healthcare Consulting.

Bottom line: "Bombard the RAC auditor with the truth," Warmack exclaims.