Posts tagged ‘OIG’

October 17, 2012

OIG focus on Medicaid

This is the second post on the OIG’s FY 2013 work plan. The first post dealt with Medicare-related issues. This post looks at HHA focuses for Medicaid issues. Note that some have a FY2014 start date. This can indicate a new focus on an item that is already being watched by OIG.

Duplicate Payments by Medicare and Medicaid: OIG will review Medicaid payments by states for Medicare-covered home health services to determine the extent to which both Medicare and Medicaid have paid for the same services. (OAS; W-00-13-31305; various reviews; expected issue date: FY 2014; new start)

Screenings of Health Care Workers: OIG will review health-screening records of Medicaid home health care workers to determine whether the workers were screened in accordance with federal and state requirements. Examples of health screenings can include vaccinations for hepatitis and influenza. (OAS; W-00-11-31387; W-00-12-31387; various reviews; expected issue date: FY 2013; work in progress.

Provider Compliance and Beneficiary Eligibility: OIG will review HHA claims to determine whether providers have met applicable criteria to provide services and whether beneficiaries have met eligibility criteria. Providers must meet criteria, such as minimum number of professional staff, proper licensing and certification, review of service plans of care, and proper authorization and documentation of provided services. (OAS; W-00-10-31304; W-00-11-31304; W-00-12-31304; various reviews; expected issue date: FY 2013; work in progress)

Homebound Requirements: OIG will review CMS policies and practices for reviewing the sections of Medicaid State plans related to eligibility for home health services and describe how CMS intends to enforce compliance with appropriate eligibility requirements for home health services. The office will also identify the number of states that violate federal regulations by inappropriately restricting eligibility for home health services to homebound recipients. (OEI; 00-00-00000; expected issue date: FY 2014; new start)

Read the entire OIG report

October 14, 2012

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

September 5, 2012

For your HHAs finanical health, OIG list is key when hiring new employees

HHAs should check the OIG’s List of Excluded Individuals and Entities (LEIE) when hiring new employees. This is key to avoiding monetary penalties.   

Cooperative Home Care in Missouri agreed to pay $121,010 for employing an individual that it knew or should have known was excluded from participation in Federal health care programs, the OIG says.

And after it self disclosed conduct to the OIG, Seasons Hospice and Palliative Care of Southern Florida Inc. in Florida,agreed to pay $73,428 for the same violation.  “Anyone who hires an individual or entity on the LEIE may be subject to civil monetary penalties,” the OIG warns on its website.

For those agencies who have never checked its contractors, employees and referring physicians,  go to http://exclusions.oig.hhs.gov/ Five names can be entered in at a time. There is also a searchable downloadable version.

Supplemental exclusion and reinstatement files are posted monthly on the OIG website so users can merge these files with a version of the List of Excluded Individuals and Entities that is stored on their computer and check monthly for any updates.

Selman-Holman & Associates, LLC is working on completing its compliance plan for home health agencies. We will perform compliance audits and provide the materials and education to implement your compliance plan.

June 5, 2012

CMS can’t collect all overpayments

The Office of Inspector General reported last week that CMS isn’t able to collect on all overpayments because of statute of limitations on collection times. As of October 2010, more than $330 million had been left behind for overpayments in FYI 2007, 2008, and part of 2009.

OIG noted that a number of obstacles, including not having adequate systems to document collections or detect data entry errors, impeded CMS’ ability to collect on overpayments.

See the full report.

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March 26, 2012

OIG finds $432 million+ in HHA claims issues

The HHS Office of the Inspector General conducted a study looking at home health claims from 2002-2008 and found that$432 million in Medicare monies were inappropriately paid either because medical necessity was not established or coding was inaccurate. Millions more dollars were lost to CMS or HHAs because of upcoding or downcoding.

The number of HHAs grew from 7,052 to 9,801, and increase of 39 percent. Medicare spending on home health increased 84 percent from $8.5 billion in 2000 to $15.7 billion in 2007. The sharp rise in payments created the push to investigate payments.

HHS reviewed the claims of almost 500 beneficiaries to see whether Medicare coverage requirements were met.

The office found that 22 percent of claims were in error because services were not medically necessary or claims were coded inaccurately, resulting in $432 million in improper Medicare payments. Also, HHAs upcoded about 10 percent ($278 million) of claims and downcoded about 10 percent ($184 million) of claims.

OIG believes it needs to investigate more to determine what services are met and what potential for fraud is involved.

Read the complete report.