Home Health & Hospice Week

Zero in on your worst documentation offenders.

If you get mired down in Recovery Audit Contractor audits and takebacks, it could severely hamper your cash flow - and even threaten your viability.

Now that the Centers for Medicare & Medicaid Services has approved the first home health topic for RAC Performant, smart home health agencies will ratchet up their preparedness. "Agencies should always be audit ready," stresses consultant Cindy Krafft with Kornetti & Krafft Healthcare Solutions. It's "never a good plan to assume silence is safe."

Heed this advice from the experts to head off RAC audits, or at least limit the damage they can inflict:

1. Know what you're up against. Learn what topics are putting you at risk. To date, CMS has approved only one home health issue for review, but experts predict approved topics will multiply - perhaps quickly.

"Regularly check the Performant website for updates and disclosures," advises finance expert Tom Boyd with Simione Healthcare Consultants in Rohnert Park, California. The RAC's site at https://performantrac.com/region-5 also contains links to resources such as ADR submission instructions, Frequently Asked Questions, and outreach materials explaining the RAC audit workflow process.

2. Implement audits. Before you get hit with a RAC audit, hit yourself with a review. Put in place "random review and claim sampling," Boyd advises. Getting outside eyes to look at them will be the most helpful.

"The best way to avoid audits is for HHAs to closely monitor their clinical record documentation to be sure all services and visits are clearly supported by the clinical notes," says consultant Pam Warmack with Clinic Connections in Ruston, Louisiana.

3. Educate your staff. For the approved review issue of medical necessity, denials are going to be based largely on documentation from your staff. Now is the time to make sure they are firing on all cylinders. "Educate staff even more diligently" than you have in the past, Warmack urges.

4. Educate referral sources. Under the RAC's medical necessity audit, the fate of your claims won't depend only on you. The physician performing the face-to-face encounter, providing F2F documentation, and certifying the plan of care will also do much of the heavy lifting, experts note. Make sure docs understand what's necessary to ensure their patients receive home care services.

5. Address software-related shortfalls. Some of the problem with agencies' documentation is how they're letting their clinicians use their software, Warmack relates. "Point of care software has not been the fix we had hoped it would be," she tells Eli. "Too many providers allow the visiting clinicians to rely solely on the clause data built into the software, rather than narrative documentation which paints a more clear picture of the patient and a thorough description of the care provided."

Everybody likes to save time and effort, but documentation standards must be met. "It is a user issue rather than a software issue," Warmack says. "The clinicians simply do not always individualize the documentation in the electronic system."

6. Focus your education. Use your audit findings to put targeted education where you most need it. "Focus on clinicians who perform poorly and even referral sources whose referrals are not 'strong' in medical necessity," Warmack recommends.

No more free passes: "Stop keeping documentation separate from clinician skills by saying 'He is such a good nurse/therapist, he just documents poorly,'" Krafft insists. "There needs to be a zero tolerance for that attitude."

7. Review all recerts. Expect long-stay patients to be high on the target list for RAC review, Boyd says. "Review and review again all recerts, particularly those patients who have more than two episodes," he urges.

The same goes for patients picked up from another agency. "If a patient has been previously treated or on service with another HHA, ask yourself why are they on service with you?" he says.

Bottom line: While it may sound "overly simplistic," Krafft exhorts agencies to "adhere to providing only the care the patient needs" - and document that care well every time.

8. Prep your finances. Your clinical side isn't the only department that needs to pitch in for RAC audit preparation. Assume claims reviewed by the RAC may not be paid timely and take actions that may be needed to secure your financial viability, Boyd recommends. That may include lining up a loan or credit line and increasing cash reserves, for example.

9. Respond to all ADRs. Additional Development Request nonresponse rate has been named a topic for Targeted Probe & Educate medical review; don't be surprised to see it added as a RAC issue as well. Track your ADR requests and responses to make sure you are hitting the mark.

10. Use your village. Support for your ADR'd claim will be stronger if you gather documentation from multiple sources. "Request copies of documentation from ER visits, physician visits, wound clinics, etc., to supplement and support the home health documentation," Warmack advises.

11. Don't send any old response. When responding to an ADR, agencies must "closely review their medical records before forwarding them to Performant to be sure that all necessary documentation is present to support the medical necessity for the services billed," Adams instructs.

Tip: "Where information is difficult to find, the HHA should establish a key for the audit reviewers to identify where specific information is found," Adams suggests.

12. Ask for the RAC's help. HHAs that may be overwhelmed by ADR numbers should monitor the volume of claims requested, Boyd recommends. "For example, if 40 records were requested and that would cause financial hardship if denied or delayed payment, then ask Performant to select 10 at a time, resolve the 10, and continue after that," he suggests.

13. Use your industry resources. "Advise your state and national association if you have been selected, and request assistance," Boyd counsels.