Home Health & Hospice Week

Have agencies learned from their initial mistakes?

In the early days of the COVID-19 public health emergency, home health agencies didn’t use much telehealth yet — but when they did, they mostly did it wrong.

Of 200 sampled claims from the March-through- December 2020 audit period, only four contained telehealth services. “None of the four claims fully complied with Medicare requirements for home health services furnished via telehealth,” the OIG finds.

The problems: “Of these four sampled claims, two did not include a provision in the plan of care allowing for the use of telehealth services,” the OIG notes. “The remaining two claims had provisions in their plans of care allowing for the use of telehealth services, but the plans of care did not tie the use of telehealth services to patient-specific needs identified in the comprehensive assessment,” the watchdog agency continues.

“In addition, for one of the remaining two claims, telehealth services substituted for a home visit ordered in the plan of care,” which isn’t allowed, the OIG explains.

Plus: While the other 196 claims in the sample didn’t include telehealth services, “we found that 60 records had plans of care that included language allowing for such services,” the OIG adds. In 58 of those PoCs, “the use of telehealth services was not tied to patient-specific needs identified in the comprehensive assessment,” the OIG found. And “in 16 of the 58 plans of care, the language suggested the use of telehealth services as a substitute for a home visit,” it adds.

The OIG gives HHAs a bit of a break for once, noting that “the errors occurred because the HHAs were unfamiliar with the Medicare requirements for such services, which were new early in the COVID-19 PHE.”

Nevertheless, it urges CMS to “monitor HHA reporting of the new G-codes [for telehealth services] to determine whether further updates to regulations or guidance are necessary.”

In a response letter, CMS Administrator Chiquita Brooks-LaSure agrees to do so. Plus, CMS already “has taken action to reduce improper Medicare payments by educating health care providers on proper billing,” Brooks-LaSure says.

Note: The report is at https://oig.hhs.gov/oas/reports/region5/52100026.pdf.