Home Health & Hospice Week

Consider serious therapy changes.

If you haven't received an audit request from your Recovery Audit Contractor yet, you could be next on the list. And a host of other government contractors are breathing down your neck too.

Take these steps to protect against RAC and other auditors' review, suggests clinical consultant Pam Warmack with Clinic Connections in Ru-ston, La.:

1. Watch and learn. "I love the saying, 'A smart man learns from his mistakes, but a wise man learns from the mistakes of others," Warmack tells Eli. "Every provider out there should be listening closely to discover what care is being denied and to what degree."

2. Make necessary changes. Look at the risk areas highlighted by RAC and other auditors' denials, then work to limit your exposure in those areas. "Every provider should be preparing a quality program designed to minimize their risk if faced with review," Warmack advises.

3. Cover your compliance bases. "Every provider should be developing a formal corporate compliance program," Warmack urges. The HHS Office of Inspector General provides home health agency- and hospice-specific compliance guidance at http://www.oig.hhs.gov/fraud/complianceguidance.asp. For in-depth compliance plan advice from the industry's legal experts, see Eli's HCW, Vol. XIX, Nos. 23 and 29.

4. Consider therapy changes. Entities ranging from the U.S. Senate to the Centers for Medicare & Medicaid Services to the OIG have been focusing on therapy in HHAs as a potential area for fraud and abuse. Take their cue and focus on your own therapy practices, Warmack counsels.

"Providers are already beginning to work with therapists to gain a level of control over therapy admissions and appropriateness of care," War-mack relates. "Many providers are beginning to add therapists to their employee rolls rather than outsourcing all therapy services."

Another step: "Quality assurance programs have begun including therapy services and requiring therapists be active participants in performance improvement programs and activities," Warmack adds.

5. Educate staff. You can't expect your staff to comply with rules and agency policies and procedures if they don't know about or understand them. "Staff education is more important than ever," Warmack stresses.

6. Hold staff accountable. Just going over the rules and requirements with your staff isn't enough. You need to give them a reason to go by those rules.

"Holding clinicians accountable for admitting only eligible patients, providing qualifying care, and documenting care at a level that ensures reimbursement is absolutely essential," Warmack emphasizes.