Home Health & Hospice Week

Bad news: HHA error rate is still much higher than average.

Don't expect Medicare to ease up on face-to-face and other documentation requirements just because the Comprehensive Error Rate Testing program has reported a second major decline in the home health agency payment error rate.

Background: Back in mid-2016, the Centers for Medicare & Medicaid Services, the Medicare Payment Advisory Commission, and others began trumpeting the 59 percent payment error rate the CERT contractor found for home health claims in 2015. CMS followed up with officially issuing the number in the 2015 CERT report published in October 2016 (see Eli's HCW, Vol. XXV, No. 38).

For 2016, the HHA error rate fell to a still high 42 percent (see Eli's HCW, Vol. XXVI, No. 16).

Now the 2017 CERT report issued Jan. 8 puts the home health error rate at 32 percent. That compares to the overall improper payment rate for all Medicare providers of 9.5 percent, CMS notes on its CERT webpage. The sampling period for the 2017 report ran from July 2015 to June 2016.

Home health agencies can be relieved that they are not the provider type with the highest error rate. That distinction goes to durable medical equipment providers with an improper payment rate of 44.6 percent, CMS notes.

And they aren't even the provider type with the second- or third-highest error rate. That would be inpatient rehabilitation hospitals with a 43.9 percent improper payment rate and chiropractors with a 41.7 percent rate.

Other provider types with fairly high error rates include inpatient rehab units (34.8 percent), clinical labs (29 percent), pain management Part B providers (25.2 percent), physical medicine and rehab providers (24.8 percent), and psychiatrists (24.1 percent).

Hospices' error rate was 14.7 percent, according to the report.

Agencies In These High-Error-Rate States May Become Audit Targets

The CERT contractor also ranked a selection of home health and hospice overpayments by state. States with the highest improper Medicare payment rates were Tennessee (42.3 percent), Indiana (37.8 percent), Texas (37.4 percent), Louisiana (35.8 percent), and Oklahoma (35.5 percent).

States with the lowest improper payment rates were Massachusetts (6.9 percent), New Jersey (10.4 percent), Virginia (10.9 percent), Michigan (13.3 percent), and California (17.9 percent).

The overall 9.5 percent error rate for Medicare represents $36.2 billion in improper payments, the report says.

Insufficient documentation was the biggest error found for all provider types, at 64 percent. Next was medical necessity (17.5 percent) and incorrect coding (13.1 percent).

Note: See the 2017 report at www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/CERT/Downloads/2017-Medicare-FFSImproper-Payment.pdf. More CERT information is at www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFSCompliance-Programs/CERT.