Office of Inspector General Continues Focus on Home Health Agencies
Friday, June 21, 2019
Posted by: Kyle Simon
Courtesy of the National Association for Home Care & Hospice (NAHC)
The Department of Health and Human Services (HHS), Office of the Inspector General (OIG) issues updates to its work plan on a monthly basis throughout the year. The OIG announced this month a revision of an issue for home health agencies (HHAs). This issue is not new to the OIG’s work plan, but appears to have been revised. The details for the revision are unknown; however, CMS continues to focus on home health agencies due to high Comprehensive Error Rate Testing (CERT) program improper payment rates.
Home Health Compliance with Medicare Requirements
The Medicare home health benefit covers intermittent skilled nursing care, physical therapy, speech-language pathology services, continued occupational services, medical social worker services, and home health aide services. For 2014, Medicare paid HHAs about $18 billion for home health services. CMS's CERT program determined that the 2014 improper payment error rate for home health claims was 51.4 percent, or about $9.4 billion. Recent OIG reports have similarly disclosed high error rates at individual HHAs. Improper payments identified in these OIG reports consisted primarily of beneficiaries who were not homebound or who did not require skilled services. NAHC will review compliance with various aspects of the Home Health Prospective Payment System and include medical review of the documentation required in support of the claims paid by Medicare. NAHC will determine whether home health claims were paid in accordance with federal requirements.
Agencies will need to ensure documentation during each visit clearly supports the need for skilled services and the beneficiary meets homebound status. The Medicare Benefit Policy Manual, chapter 7, provides CMS’ coverage guidelines and documentation expectations to support coverage.