The Office of Inspector General (OIG) for CMS has released their mid-year work plan for the remaining portion of the year. As always, home health and hospice is very clearly called out for potential abuse, fraud and waste.
Agencies should be very aware of billing practices including a full understanding of what items are required to be in possession before releasing a RAP for payment. The OIG is clearly aware that many new agencies and agencies in certain geographic areas are more prone to fraudulent activity than others. Besides making sure that all documentation is received before releasing a RAP, agencies should ensure that all documentation is present before releasing the final claim (end of episode claim).
The OIG has stated that 25% of agencies (1 in 4 agencies) across the nation are flagged for questionable billing process. With a total of approximately 11,400 agencies, that amounts to roughly 2,800 agencies that are deemed to be non-compliant.
Is your agency one of these? The typical profile for a non-compliant agency is a smaller, free standing agency that was accredited within the past two to three years. While non-compliance may be based on lack of education rather than willfulness to ignore the rules, agencies such as these will be under scrutiny in the coming months and year.
Please also remember that while the OIG may investigate your agency directly, the OIG can also recommend to CMS and your Intermediary a review of claims, billing practices and documentation standards. For smaller agencies, this can basically cause a complete shutdown of operations and cash flow.