The OIG has issued a detailed Advisory Opinion (OIG Advisory Opinion No. 15-12) regarding pre-admittance visits by home health agency staff. This is great news to agencies who frequently use liaisons within hospitals to assist office staff and clinical staff in admitting a new patient for care.
The OIG opinion advisory indicates that agencies who send staff to the hospital in order to introduce themselves and the agency they represent provide no monetary value. However, OIG did admit that the visits do provide intrinsic value. Ultimately, because no money or potential value that can be converted into a dollar amount is present, agencies can continue this practice.
Staff as outlined by the advisory can include professional staff such as RNs, LPNs and therapists, but also may include non-medical staff such as marketing and sales staff. This single definition of staff helped form the OIG’s opinion as the introductory visit does not trigger any billable visits or time – therefore not creating the monetary value or potential anti-kickback trigger, because no medical training is necessary to perform the introduction.
Let’s make this ruling work to your agency’s advantage. If you already have marketing staff performing pre-admit visits to patients, you will want to read this to make sure you are in compliance. If you are not performing these types of marketing activities, you should because your agencies referral potential is much greater than agencies who sit and wait for the hospital to call with a patient. Another way to view this type of program is as a means to prevent another agency from swooping in and stealing the patient. This seems to happen in certain areas around the country, but such a program could help deter this situation.
A pre-admission program must follow these compliance policies in order to not create a situation where potential monetary benefit is derived:
- Patients Must Only Receive Introductory Information
You agency can only provide general information about your agency such as a brochure regarding services and whom to contact for care. As a personalized measure however, your agency can share with the future patient information on who will be providing care such as photos and an overview of what home health is. During this overview you can explain services covered and not covered by their Medicare home health benefits under Part A. The purpose is to educate and help the patient understand the importance of compliance in order to receive home health services.
- No Medical Services
Your staff member who visits with the patient and introduces your agency cannot provide any type of service that could be billable under Medicare guidelines. This is simply a meet and greet that focuses on compliance and getting to know one another by answering questions. Technically, a non-medical staff member such as a marketer could make this visit rather than a nurse or therapist.
- Safety Precautions
Your visit to the hospital to meet with the patient before admission allows the agency to provide a higher level of security to the patient. The patient will know who should be arriving at their home within the next 48 hours and which agency that person represents. This is critical to be one step ahead of some agencies who like to swoop in before the chosen agency is able to open the patient.
While this might be something your agency has explored or is now doing, OIG’s position is that pre-admittance meet and greets are an acceptable tactic used by agencies. This is also a great marketing tactic to implement, as it deepens the level of commitment to important referral sources, hospitals. You also deepen your ties to patients who may request you automatically when the need for services arises again. Please contact us if you would like more information on setting up this type of program for your agency.