Home Health & Hospice Week

Take the auditing into your own hands.

The latest home health agency audited by the OIG isn't taking the findings lying down, and neither should you.

"People better wake up," warns consultant Sparkle Sparks with Redmond, WA-based OASIS Answers Inc. The OIG has assessed whopping overpayments for four HHAs so far. "Do you think they're just going to drop it now?"

Oxford Healthcare in Springfield, MO implemented a three-step plan to strengthen its therapy pro-cesses after the HHS Office of Inspector General assessed a whopping six-figure overpayment based on review of high-therapy claims.

Oxford's plan is "right on the money," cheers Sparks, a physical therapist. If other agencies follow Oxford's lead, they can cut down on most of their therapy-related liabilities, she judges.

Learn by example: Here's what Oxford did after the feds came knocking:

1. Furnished therapist education. Oxford conducted mandatory general education sessions for all therapists as well as one-on-one education. The general sessions covered home exercise programs, physician orders, patient goals, medical necessity and interdisciplinary communication. One-on-one sessions conduct ed by chart auditors focused on therapists' specific documentation problems.

HHAs that contract out for therapists may find education a big challenge, acknowledges consultant M. Aaron Little with BKD in Springfield, MO. But agencies need to pursue the issue, Little urges.

Supervision of contract therapists is vital, Sparks stresses. "No matter who is providing them, you need to know those therapy services are medically necessary." Otherwise, agencies with contract therapists are putting themselves at risk of big overpayments and even fraud and abuse charges.

2. Audited therapy records. Oxford increased its internal audits of therapy records and claims. "Clinicians do not seem to understand how critical it is to document appropriately," Sparks charges. Sloppy documentation is just not going to cut it with therapy in the hot seat.

Have both therapists and non-therapists review charts of discharged and active patients, advises Cindy Krafft, director of rehabilitation for OSF Home Care based in Peoria, IL. "Look at documentation from the viewpoint of a payer," urges Krafft, a PT. "Would you pay what you are being asked to pay for the services provided?"

Use your audits to make sure your education is sinking in, Sparks recommends. When you find problems, use them to fuel further educational efforts.

3. Increased interdisciplinary communication. Many providers fall into the trap of having an interdisciplinary communication tool that is merely a box to check off rather than a meaningful exchange facilitator, Sparks cautions. Implement and enforce processes to increase communication.

Take action: Here are a few more tips to help keep your therapy visits kosher:

4. Tie documentation audits to billing. Often HHAs make the mistake of having no relationship between the chart audit and the billing, Little points out. "I've been to many agencies where there was strong emphasis on compliance and 100 percent chart review, but the review happened independently from the claims billing process." That leads to problems like claims being billed before the physician signs the plan of care.

Keep communication lines open between clinicians and billers to minimize those types of billing mistakes, Little recommends.

5. Use billing checklists. To help know when to bill--and when not to--agencies can use tools with specific billing questions like, "If therapy was provided, has physician-signed and dated therapy plan of care been received?" Little offers. Staff can use the forms or checklists as ways to initiate communication between chart auditors and billers.

Reality check: HHAs should remember that they can't go back and fix problems that occurred during the time periods the OIG is auditing, says Krafft, who is also vice president of the home health section of the American Physical Therapy Association. But they can use their audit findings to improve therapy processes going forward. 

Note: More details of Oxford's therapy plan are in the OIG report at www.oig.hhs.gov/oas/reports/region7/70401010.pdf.