Home Health & Hospice Week

Don’t forget about appeals.

Home health agencies affected by Targeted Probe and Educate review, or those just wanting to stay off the TPE radar, should focus on the program’s top denial reasons.

“Most all areas relate to poor documentation or knowledge deficit, particularly regarding face-to-face, plan of care, and recerts for home health,” highlights Sharon Litwin with 5 Star Consultants in Camdenton, Missouri.

Litwin advises providers to:

• make sure they have a good intake process for F2F;
• follow up and work with physicians to ensure they have all required documentation; and
• ensure the F2F reason is consistent with the home health primary reason/diagnosis.

And, as always, HHAs should be certain “of course, that the plan of care is patient-specific, has measurable goals, and has appropriate interventions,” Litwin adds.

Don’t forget: Recerts must indicate a continued skilled need, Litwin advises. HHAs that are having difficulty with these requirements may need outside help to get up to speed, she suggests.

HHAs facing TPE denials can zero in on their particular problem areas by carefully analyzing the feedback they get in their one-on-one education calls from the MAC. Remember, “providers found to be non-compliant at the completion of Round 1 will advance to Round 2 of TPE at least 45 days from completion of the 1:1 post probe education call date,” HHH Medicare Administrative Contractor CGS says in its TPE results article.

“The education calls will be very important for all agencies to do to see exactly what the issue is,” Litwin stresses.

But don’t wait until you are on TPE to play defense, urges consultant Joe Osentoski with QIRT in Troy, Michigan. “The moral” of the latest results “is to not get targeted,” he says.

In that vein, “CGS offers education at any time for providers,” the MAC says in the TPE results article. “Providers do not have to be identified for TPE to request education. CGS encourages providers to request education and conduct self-monitoring based on our posted Medical Review Activity Log and using tools such as Comparative Billing Reports (CBRs) offered through our web portal.”

Plus: If you find denials under TPE are unfounded, exercise your right to appeal, Litwin urges. “If all agencies do this and can … have them overturned, maybe that will show CMS/OIG that the TPE system is the flaw,” she exclaims.

There should be fertile ground for appeals, expects Lynn Olson, owner of billing company Astrid Medical Services in Corpus Christi, Texas. For example, AMS has seen “providers informed the FTF was not included with the documentation, even though many of the providers had included the documents. There was not a clarification if the FTF was incomplete, date errors, etc. When providers resubmitted the FTF, unchanged, it was accepted and the claim paid,” Olson relates.

Note: For more tips on staying off or defending against TPE, see Eli’s HCW, Vol. XXVII, Nos. 11, 21, and 32.