OIG FY2013 work plan is out

The Office of the Inspector General work plan for home health agencies (and all providers) was just released. As usual, OIG is telling us exactly what we need to pay attention for the upcoming fiscal year, starting Oct. 1, 2013. The highlights are below:

Face-to-Face Requirement: OIG wants to see how well HHAs are complying with new F2F requirements.F2F encounters must occur within 120 days: either within the 90 days before beneficiaries start home health care or up to 30 days after care begins. (42 CFR § 424.22.) (OEI; 01-12-00390; expected issue date: FY 2013; work in progress. Affordable Care Act.)

Employment of Home Health Aides With Criminal Convictions: OIG wants to see the rate of compliance with state requirements for criminal background checks for HHA applicants and employees. Federal law requires that HHAs comply with all applicable State and local laws and regulations. (Social Security Act, §1891(a)(5), implemented at 42 CFR § 484.12(a).) A previous OIG review found that 92 percent of nursing homes employed at least one individual with at least one criminal conviction. (OEI; 12-12-00630; expected issued date: FY 2013; work in progress)

States’ Survey and Certification: Timeliness, Outcomes, Followup, and Medicare Oversight: OIG will review the timeliness of HHA recertification and complaint surveys conducted by State Survey Agencies and Accreditation Organizations, the outcomes of those surveys, and the followup of complaints against HHAs. The office will also look at CMS oversight designed to monitor HHA surveys. (OEI; 06-11-00400; expected issue date: FY 2013; work in progress)

Missing or Incorrect Patient Outcome and Assessment Data: OASIS is a focus. OIG will look at OASIS data to identify payments for episodes for which OASIS data were not submitted or for which the billing codes on the claims are inconsistent with OASIS data. (OAS; W-00-13-35600; various reviews; expected issue date: FY 2013; new start)

Medicare Administrative Contractors’ Oversight of Claims: OIG will review the activities that CMS and its contractors performed to identify and prevent improper home health payments from January to October 2011. (OEI; 04-11-00220; expected issue date: FY 2013; work in progress)

Home Health Prospective Payment System Requirements: OIG will look at compliance and documentation with various aspects of the home health PPS, including the documentation required in support of the claims paid by Medicare. This includes looking at services including part-time or intermittent skilled nursing care, as well as other skilled care services, such as physical, occupational, and speech therapy; medical social work; and home health aide services. (OAS; W-00-12-35501; W-00-13-35501; various reviews; expected issue date: FY 2013 ;work in progress and new start)

Trends in Revenues and Expenses: OIG will review cost report data to analyze HHA revenue and expense trends under the home health PPS to determine whether the payment methodology should be adjusted. (OAS; W-00-10-35428; various reviews; expected issue date:FY 2013; work in progress)

I’ll have a post on more of the OIG report soon.

Read the entire OIG work plan

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