Home Health & Hospice Week

Your referral sources who bill for advance care planning may want to brush up on the requirements, in light of new scrutiny on the topic.

In a new report, the HHS Office of Inspector General reviewed 691 ACP services associated with 125 beneficiaries. “Providers did not comply with federal requirements for 466 services totaling $33,332,” the OIG found. The watchdog agency gave the thumbs up to 225 services totaling $15,874.

Based on the sample, the OIG “estimated that Medicare providers in an office setting were paid approximately $42.3 million for ACP services that did not comply with federal requirements,” according to the report.

Among the problems the OIG found were failure to “distinguish between time spent face-to-face with the beneficiary discussing ACP and time spent on concurrent services;” no documentation of ACP services at all; and provider failure to respond to medical record requests.

In a response letter, CMS agrees to educate physicians and other practitioners about ACP documentation requirements and to direct recoupment of the payments found to be unsupported.

The 22-page report is at https://oig.hhs.gov/oas/reports/region6/62004008.pdf.