Self-reporting a weak point.
Don’t think a new outlier payment methodology will eliminate the fraud that has hounded this portion of the Prospective Payment System.
Shifting to the per-unit outlier calculation “may result in fraudulent calculation of the time necessary to provide the service,” warned the California Association for Health Services At Home in its comment letter on the 2017 Home Health PPS proposed rule.
“This per-unit outlier payment methodology invites the opportunity to game the outlier payment system because it relies on self-reported time records,” agreed HealthSouth in its comments. “Unscrupulous HHAs will be able to increase their revenue ... under the guise of ‘caring for more complex patients’ by artificially inflating the time spent with patients or simply misreporting the units that were actually delivered. We ask CMS to offer safeguards to protect against such troublesome activity.”
One way to help is by furnishing more clear unit-counting instructions, commenters agreed. For example, HHAs would need guidance on whether to round up minutes when counting units.