OIG Work Plan Spotlights Home Care Issues

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Karen Utterback By Karen Utterback 
Former Vice President, Product Marketing and Strategy, McKesson (Retired)
OIG Work Plan Spotlights Home Care Issues

Earlier this year, the HHS Office of Inspector General (OIG) released its 2014 work plan, which includes several items of note for home health and hospice agencies. Specifically, the plan includes a review of how well agencies are complying with payment regulations and criminal background check requirements. The office also plans to look into potential hospice general inpatient care misuse and changes to the hospice payment system.

HHS OIG plans to look at length of stay, levels of care received and common illnesses of Medicare beneficiaries who receive hospice care in assisted living facilities. The report says this is part of a larger effort to help CMS reform the hospice payment system and develop quality measures for hospices, as required by the Affordable Care Act. According to the report, assisted living facility residents have the longest lengths of stay in hospice care, and the Medicare Payment Advisory Commission believes these stays bear monitoring and examination.

HHS OIG also will review hospice medical records to determine whether hospice general inpatient care is being misused. The report points out that when a beneficiary elects hospice care, the agency assumes the responsibility for medical care related to the beneficiary’s terminal illness and related conditions and that the patient may revoke that care choice and return to standard Medicare coverage at any time.

For home health agencies, the criminal background review seems straightforward. The report notes that a previous OIG review found that 92% of nursing homes employed at least one individual with a criminal conviction. Nearly all states have laws prohibiting healthcare-related entities from employing individuals with prohibited criminal convictions.

The office’s work on fraud stems from an OIG finding that one in four home health agencies had questionable billing. The office plans to “review compliance with various aspects of the Home Health Prospective Payment System, including the documentation required in support of the claims paid by Medicare.”

A clinical management and agency management software solution can help provide the proper documentation that CMS and oversight agencies such as OIG require for patients who use Medicare or Medicaid.

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