Fraud & Abuse:
Will The OIG Scare Your Docs Away From CPO?
Published on Fri Oct 15, 2004
Annual work plan also targets therapy upgrade, rehospitalizations among hot spots. All your hard marketing work may go down the drain as the OIG plans an assault on physician care plan oversight.
CPO claims are on the HHS Office of Inspector General's hit list for this fiscal year, the watchdog agency reveals in its latest work plan. A jump in CPO reimbursement from $15 million in 2000 to $41 million in 2001 has made the feds cast a suspicious eye on the physician payments for 30 minutes or more of qualified management activities regarding home health patients.
In an earlier study of CPO claims in Puerto Rico, none of the claims met the requirements for CPO billing, said a hard-hitting OIG report released early this summer (see Eli's HCW, Vol. XIII, No. 19, p. 146). And physician Part B carriers have issued restrictive CPO billing rules.
Those developments may have dampened some of physicians' enthusiasm for the home health-related payment. But further OIG reports, as promised in the work plan, could send docs running scared from CPO billing altogether, experts worry.
Make or break it: CPO is still very under-used by physicians, points out Bob Wardwell with the Visiting Nurse Associations of America. "So the results of this study could promote its appropriate use or recreate the same panic among physicians that caused many to avoid home health referrals," Wardwell worries.
Such a panic could threaten HHAs' relationships with their referring physicians if the agencies have used CPO as a significant marketing tool. Also, physicians could be less willing to refer patients to home care if they identify the benefit with fraud or abuse threats.
Physicians may end up viewing CPO billing as a "fraud trap," warns Wardwell, a former CMS top official. And it reminds docs of their responsibility to police the home health benefit - a burden they may not be happy about and would rather avoid by not making home care referrals.
Other HHA issues in the work plan include: Rehospitalizations and ER visits. The OIG wants to scrutinize quality in home care under the prospective payment system, and the agency plans to use rates of rehospitalization and emergency room visits to monitor quality of care, the work plan indicates. But home care providers think those two indicators aren't very representative of quality.
"We have some concerns about these two measures," says Brian Ellsworth with the Connecticut Association for Home Care. Too many outside variables besides HHA care affect these measures, Ward-well agrees.
For example, patients who are Medicaid-eligible have higher rates of hospitalization than those who don't, CAHC points out in a recent comment letter to the National Quality Forum. NQF is considering recommending the measures for publicly reported outcomes.
That difference is due to the [...]
