The OIG has released its work plan for next year and should yield some interesting results. As you are well aware, the OIG likes to make sure that their investigations and favorable outcomes to the government are widely circulated to various media outlets.
Home Health Focus Areas:
Agencies that have newly been awarded a provider number should take notice. The OIG has you in their crosshairs. This because data from a prior OIG report indicated that 25%, or 1 in 4, new providers engage in possible waste, fraud or abuse of the Medicare benefit. The OIG will be focusing on the documentation required to bill Medicare and ensuring that agencies have all of the documentation before a claim is submitted.
We are recommending all agencies use a pre-billing audit tool and save this tool in the patient record – either electronically or on paper in the patient’s chart. Although many software/EMR providers restrict billing from taking place before documentation is received and approved, an extra step should be taken – especially by newer providers, who will be the largest group to be examined by the OIG.
All agencies should expect the possibility of being targeted for an audit to ensure that none of your staff are convicted of crimes that would disqualify the staff member from working in healthcare. While the likelihood of most agencies hiring a criminal is very slim, the OIG wants to make sure agencies are complying with all local, state and federal background check regulations. This audit and compliance verification will extend to employees and contracted staff.
We are recommending that all agencies perform a full background check on employees every 2-3 years and that this information be placed in the private personnel file of the employee.
Hospice Focus Areas:
Assisted Living Facility (ALF) Residents
The OIG has decided to look at why so many ALF residents are on service with hospice. The OIG is going to focus on length of stay (how long the ALF resident is receiving services with the hospice provider), levels of care received, and common terminal illnesses of the patients who are receiving care. Obamacare requires CMS to revise payments to hospice providers and also requires hospice providers to report quality data. The amount of time an ALF resident is on hospice services has prompted the OIG to begin investigating hospice providers. The OIG believes that there could be patients receiving hospice rather than home health due to the much higher margins associated with hospice reimbursement. The OIG is following the recommendation of MedPac, who stated that hospice stays are increasing in length and are too long now.
We recommend hospice providers evaluate questionable patients as to their overall likelihood of recovery from illness. The OIG work plan makes specific mention of whether or not a patient is going to be curable. We have heard from many home health providers that providers who only provide hospice care are frequently putting patients on service for extended periods, when it is not needed and the patient would benefit from curative home health treatment.
Be ready and make sure your agency is compliant. The OIG has very strong and large reaching powers that can do significant damage to your agency, even if you are found to have not done anything wrong. The basic association of an OIG investigation with your agency can permanently harm your reputation and ability to conduct business.