Home Health & Hospice Week

Just having time sheets isn't enough to guarantee a community education coordinator's salary, the Provider Reimbursement Review Board says in a recent decision.

Those time sheets must be detailed enough to distinguish between reimbursable education and non-reimbursable marketing activities, the PRRB says in a May 2 decision (No. 2003-D27).

Colonial Heights, VA-based Home Town Health Care's coordinator's time sheets were too vague to prove his salary reimbursable, regional home health intermediary Cahaba GBA claimed for Home Town's 1997 cost report. And the Board agreed, judging the time sheets as insufficient documentation, according to the decision.

But Home Town succeeded with most of its other contentions in the case. The Board reversed Cahaba's creation of a non-reimbursable cost center for Heaven Sent Nursing Services, a private duty HHA owned by Home Town's owner. "The Board finds that the Provider and Heaven Sent were separately incorporated, independently licensed, maintained separate checking accounts, and filed their own separate corporate tax returns," says the decision. "Also, for the year at issue, each entity had a separate lease and a separate location."

While Home Town's owner did draw a full salary from Home Town in addition to a salary from Heaven Sent, documentation was sufficient to justify the salary, the PRRB found.

But Home Town's owner didn't get to keep all of that salary. Cahaba disallowed a portion of the salary as excessive and disallowed more by allocating it to the non-reimbursable cost center for Heaven Sent, resulting in only about $30,000 of the originally paid $114,000 being reimbursed.

Since the Board nixed the non-reimbursable cost center, that disallowance was reversed. But the PRRB did agree with Cahaba that the salary was excessive. However, Cahaba's suggestion for an appropriate salary wasn't adequate. "The intermediary is obligated under the Medicare regulations and manual to develop information that can be used to evaluate reasonableness of executive compensation," the decision notes.

Home Town actually furnished better owner's compensation data from the 1997-1998 Homecare Benefits & Salary Report, and the Board adjusted the allowable salary to almost $83,000 based on that data.

Finally, the Board reversed Cahaba's $7,400 disallowance of a TV commercial from Home Town. The intermediary argued the ad aimed to increase patient utilization, but Home Town said the ad stressed that patients have a free choice of home care providers. Home Town ran the ad after two hospitals in its area opened their own HHAs.

The ad, which emphasized a patient's free choice of providers and didn't mention Home Town's specific services, "fits squarely within" advertising guidelines, the Board said.

Home Town didn't respond to a request for comment.