Home Health & Hospice Week

Cheating by providers too easy under current protocol, report concludes.

Expect increased micromanagement of how you generate your patient roster for surveys, if one watchdog agency gets its way.

The problem: When the HHS Office of Inspector General checked home health agency generated patient lists for 28 surveys against claims data, nine of the rosters "were incomplete," the OIG says in a new "Risk Alert" report, "Reliance on Unverified Patient Lists Creates a Vulnerability in Home Health Surveys." One of the rosters was "missing more than 150 - or nearly 90 percent - of the HHA's active beneficiaries," the report says.

"HHAs that wish to avoid scrutiny of certain patients - for example, to conceal fraudulent activity or health and safety violations - could intentionally omit those patients from the lists they supply to surveyors," the OIG warns. Given the industry's susceptibility to fraud, abuse, and waste, the Centers for Medicare & Medicaid Services should be concerned about this vulnerability, according to the report.

Another problem: At one agency, four patients were discharged on the day of the survey for no apparent reason and were later picked back up for service, the OIG adds.

The solution: There's no way for surveyors to get a real-time patient roster independent of the HHA, unfortunately, the OIG notes. But the report does suggest ways for surveyors to mitigate the cheating agencies can do when compiling rosters.

One strategy to minimize patient roster shenanigans is creating or adapting OASIS-based reports for surveyors. "While such reports would be limited by the absence of some recently admitted patients, they would represent an improvement over relying on HHA-supplied patient lists alone," the OIG says.

Other ways to limit agency manipulation of survey rosters are to check the patient lists against claims data retrospectively (which would require that surveyors keep the rosters); monitoring HHA staff as they retrieve the roster information; and confirming that a certain patient subset is on the lists (for example, by interviewing a clinician and checking that all her patients are on the roster).

See the report at https://oig.hhs.gov/oei/reports/oei-05-16-00510.asp.