Home Health & Hospice Week

Home health errors account for 10% of overall Medicare improper pay rate.

Dec. 10 came and went without home health agencies in Illinois having to undergo the launch of the much-detested Review Choice Demonstration. While the home care industry would dearly love to see RCD scuttled for good, there are no clear signs pointing that way at the present.

The Centers for Medicare & Medicaid Services had signaled in a Sept. 27 Federal Register notice its intention to launch RCD, a mostly intact version of the previous Pre-Claim Review demonstration, on Dec. 10 (see Eli’s HCW, Vol. XXVII, No. 35).

But, according to a Dec. 10 post on CMS’s RCD webpage, Medicare officials are keeping the program on hold while they await Office of Management and Budget approval. CMS “is continuing the process for Paperwork Reduction Act (PRA) approval for the Review Choice Demonstration for Home Health Services,” the site says. In a November education call on RCD, CMS officials indicated that such a delay for a PRA wait could occur (see Eli’s HCW, Vol. XXVII, No. 43).

Industry veterans hope the latest Medicare payment error rate figures released by the Department of Health & Human Services may be holding up the program — for now, and for a long time coming. CMS announced in a Nov. 15 blog post that the home health payment error rate took a sharp dive to 17.61 percent for 2018 (see Eli’s HCW, Vol. XXVII, No. 42). That compares to 59 percent for 2015, 42 percent for 2016, and 32 percent for 2017. The latest figure covers the period from claims processed between July 1, 2016, and June 30, 2017.

More details are now available in a more in-depth report on the overall Medicare payment error rate, gathered through the Comprehensive Error Rate Testing program. For example, the percentage of HHA claims reviewed that contained errors was 26.6, reveals the report posted Nov. 30.

More facts revealed in the report:

• Home health improper payments account for 9.8 percent of Medicare’s overall improper payments.
• Insufficient documentation was the reason for 61.9 percent of home health claims’ improper payments.
• Medical necessity accounted for 19.2 percent of home health claims’ improper payments; no documentation 2.0 percent; incorrect coding 0.5 percent; and “other” 16.2 percent.
• The rate estimates are based on reviews of 1,175 home health claims.
• Home health claims’ underpayment rate was a tiny 0.1 percent representing $4,036.
• A home health claims error showed up in the top 5 root causes of insufficient documentation errors for Medicare claims — “Home health certification requirements, in entirety or an element, was not submitted” affected 102 claims.

CMS Signals Plan To Proceed with Demo

Industry representatives hope the muchreduced error rate for the industry could put RCD on hold for good. “These sharp reductions in improper payments demonstrate that [CMS’s] plan to initiate the Review Choice Demonstration is unwarranted,” the National Association for Home Care & Hospice insists in its member newsletter. The “improper payment rate for agencies is decreasing — without such a drastic measure that is very likely to lead to disruption of patient care,” the trade group argues.

But HHAs in Illinois and the other states scheduled for RCD shouldn’t hold their breath. “After PRA approval is received, we will update this website with the final, approved demonstration information, including a start date for home health agencies in Illinois and instructions on the choice selection process,” CMS says on the RCD webpage. “CMS will provide notice on this website before phasing in the other demonstration states: Ohio, North Carolina, Florida, and Texas.”

Note: See the 85-page CERT report at www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/CERT/Downloads/2018MedicareFFSSuplementalImproperPaymentData.pdf.