Home Health & Hospice Week

Tip: Double-check reviewer decisions to make sure waivers are considered.

Now’s the time to take action, as Medicare ramps back up its post-payment claim scrutiny.

COVID-19-era claims are up for review now (see related story, p. 162). Consider this advice from the experts to minimize the damage:

1. Keep an eye out for reviews. The shift back to more post-payment review may catch some home health and hospice agencies off guard, predicts reimbursement expert M. Aaron Little with BKD in Springfield, Missouri. “Providers need to be diligent in watching for claims being selected for post-pay review so they aren’t missed, since that communication happens via mail rather than the electronic way of notification for pre-pay review,” he points out.

2. Self-review. You may be overwhelmed and short of staff, but you still need to put in effort to make sure you are responding as completely to medical review requests as possible. “With all the challenges the pandemic has presented, I think carefully reviewing the documentation internally before it’s submitted to the MAC is really important to feel confident the documentation and practices at the time don’t present any unnecessary risk exposure,” Little tells AAPC.

3. Focus on hot spots. COVID-19 brings up a number of waiver- and flexibility-related risk areas.

For example: “If there is one part of charting that has significantly changed, it is the increase in telehealth, by both agencies and physicians,” highlights appeals expert Joe Osentoski with Gateway Home Health Coding & Consulting in Madison Heights, Michigan. Double-check everything before it goes out the door, Osentoski urges.

Another example: Agencies should “ensure that they have everything they need in the F2F encounter documents,” urges Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tennessee.

You can also look up what post-pay review topics HHH Medicare Administrative Contractors currently have running at the MAC websites:

* Palmetto GBA www.palmettogba.com/palmetto/jmhhh.nsf/DIDC/9NNJBX6701~Medical Review

* National Government Services www.ngsmedicare.com/ngs/portal/ngsmedicare/newngs/home-lob/pages/compli­anceandaudits/medical-review/medical-review-focus-areas

• CGS www.cgsmedicare.com/hhh/medreview/activitylog.html (note only the post-payment topics are active)

Remember, post-payment reviews are service-specific, not provider-specific, NGS says on its medical review webpage.

4. Check for reviewer errors. Reviewers may get confused when it comes to which waivers and rules apply at which times. “For any medical reviews for dates of service during the current PHE, providers will want to carefully examine the review decision to ensure that any PHE waivers and flexibilities were considered,” recommends the National Association for Home Care & Hospice in its member newsletter.