Home Health & Hospice Week

Industry Note:

Medical Necessity Drives OIG Audit Findings

Virgin Island HHA under the watchdog agency’s microscope.

Sloppy documentation could mean an overpayment approaching $200K for one home health agency, thanks to an HHS Office of Inspector General audit.

The OIG audited 253 claims from Sea View Health Care Services Inc. in St. Thomas, V.I., and found 122 didn’t comply with Medicare billing requirements, according to a new report. The errors on the 2012 and 2013 claims resulted in about $110,000 in overpayments during that time period.

Extrapolated to all the agencies’ claims for those years, the OIG estimates that Medicare overpaid Sea View by more than $184,000.

Biggest culprit: The OIG dinged Sea View on medical necessity in 45 of the claims reviewed, claiming the agency’s documentation didn’t support the need for nursing and/or therapy skilled services, according to the report.

The OIG also cited a failure to prove homebound status for 17 claims, and various errors with physician documentation (ranging from face-to-face to the plan of care) for 16 claims.

Plus: The OIG also took Sea View to task because OASIS answers did not match up with the HIPPS codes the agency billed for a whopping 77 claims. Although this problem affected the highest number of claims, it led to the lowest amount in overpayments — about $17,000 as opposed to $40,000 for medical necessity issues, $31,000 for homebound problems, and $21,000 for physician documentation and signature problems.

Sea View successfully rebutted some of the initial determinations by the OIG, the watchdog agency notes in the report. “We are committed to improving our processes and remain committed to having an active and strong compliance program,” the agency says in its response letter to the draft report.

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