Home Health & Hospice Week

With Medicare rules and regulations more confusing than ever, you may end up needing to use the HHS Office of Inspector General’s self-disclosure protocol — and that protocol has changed.

The policy updated last month requires a number of new things, including that providers make self-disclosures through the OIG website and increasing minimum amounts to qualify for self-disclosure. (See OIG.HHS.GOV/SDP for more changes.)

Timelines, content requirements, and damage calculation methodology has not changed, the OIG emphasizes.

“Self-disclosure gives persons the opportunity to avoid the costs and disruptions associated with a Government-directed investigation and civil or administrative litigation,” the OIG notes.

One such home health agency that took advantage of the SDP is the Visiting Nurse Association and Hospice of Vermont and New Hampshire Inc., the OIG points out on its Enforcement Actions webpage.

After it self-disclosed conduct to the OIG, VNH agreed to pay $2.4 million “for allegedly violating the Civil Monetary Penalties Law,” the agency says. The “OIG alleged that VNH submitted claims for home health services based on orders signed by a qualified clinician but not cosigned by a physician or allowed practitioner.”