Home Health & Hospice Week

The HHS Office of Inspector General thinks the Centers for Medicare & Medicaid Services should be more proactive about overseeing your face-to-face physician encounter documentation — and that’s going to mean more F2F medical review in your future.

“CMS oversight of the face-to-face requirement is minimal,” the OIG criticizes in its newly released compendium of unimplemented recommendations. “It does not have a specific program to oversee compliance with this requirement; rather, it reviews documentation when conducting medical record reviews as part of general fraud-fighting efforts, but only a fraction include the face-to-face document.”

The OIG “found that 32 percent of home health claims that required face-to-face encounters during 2011-2012 did not meet Medicare’s documentation requirements, resulting in $2 billion in payments that should not have been made,” it blasts in the report.

Watch out: CMS is putting its Supplemen-tal Medical Review Contractor on the case, the agency reportedly told the OIG. The OIG is reviewing CMS’s plan for SMRC review of F2F documentation.

Hospices don’t escape the OIG’s notice in the compendium either. The OIG wants CMS to implement a post-acute transfer policy that would prorate hospitals’ DRG payments if the patients transfer to hospice early.

Medicare would have stripped about $602 million from hospital payments by having such a policy in place in 2009 and 2010, the OIG notes.

See the compendium at http://oig.hhs.gov/reports-and-publications/compendium/files/compendium2015.pdf.