Home Health & Hospice Week

HHAs powerless to affect docs’ documentation, feds admit.

For once, home health agencies aren’t taking all the blame when it comes to the Medicare improper payment rate for the industry.

The Government Accountability Office recently issued a report outlining the physician documentation problem that has plagued home health agency claims for years. The Centers for Medicare & Medicaid Services “does not require A/B MACs to educate referring providers on documentation requirements for ordering DME and home health services because referring providers do not bill for any DME or home health services on these orders,” the GAO notes in its report. “DME suppliers and home health agencies are responsible for submitting a proper written order from the referring provider to receive payment, and DME and HH+H MACs are required to educate DME suppliers and home health agencies — but not the referring provider — on a proper written order. However, when a DME supplier or home health agency accepts a written order, its payment may be denied if the claim is reviewed and the referring provider’s medical record documentation does not support the supply or service provided.”

The GAO goes a step further and acknowledges that even MAC education may not solve this problem. “There would still be a lack of incentive for referring providers to bill properly for DME and home health services because they do not experience any repercussions for insufficient documentation — one type of improper billing,” the report continues.

“Instead, when DME or home health claims are denied due to insufficient documentation, from either the supplier or the referring provider, the DME or home health provider loses the payment, while the referring provider does not.”

Insufficient documentation is the most common reason for improper payments for home health services and DME. For fiscal year 2016, home health services had a 42 percent improper payment rate with the program paying $7.7 billion improperly, the report notes. DME had an even higher 46 percent error rate.

Despite the futility noted in the report, the GAO urges CMS to “explicitly require that A/B, DME, and HH+H MACs work together to educate referring providers on documentation requirements for DME and home health services.” The Department of Health & Human Services concurs with the recommendation in its comment letter on the draft report.

HHS also “recognizes the role of referring providers in ensuring proper billing for Medicare services,” it says in the letter.

The GAO also urges CMS to implement performance metrics for its Probe & Educate medical review campaigns (see story, p. 122).

See the 33-page report at www.gao.gov/assets/690/683312.pdf.