The home health industry should keep its collective eye on the U.S. Department of Health & amp; The Human Services Office of the Inspector General’s (HHS-OIG) recent revisions of the hospice industry because it may soon be the next.
As the home health field continues to grow, so has federal oversight and the controls attached to the industry.
Experts at Husch Blackwell have followed this trend through the hospice industry and have gleaned knowledge from it.
“As we’ve been following and reporting on these hospice reviews, OIG has also been looking at home health spaces,” Bryan Nowicki said this week on a podcast episode of Hospice Insights. “They are very similar in overall structure to what we have been working on with hospice. They are looking for certain types of errors that they have identified as recurrent or ‘top of mind’ in the field of home health.”
When OIG first began its hospice audits in 2021, the office looked for things as if recipients met the definition of being confined to a home; whether they really needed skilled services; whether the OASIS information was submitted in a timely manner; and whether services were properly documented.
Those were the four priorities reviewed by the OIG, Nowicki said. Now OIG is increasing these efforts and focus areas, this time for home health agencies.
“Honestly, these are pretty recurring problems in home health,” Nowicki said. “We would expect more of the same, but [the audit process] will be guided by what they actually find. Audits are happening now, and OIG’s goal is to start issuing final audit reports and publishing them on their website by 2023.”
Unlike many audits, results from the OIG audits are published, creating even more anxiety from the industry, according to Husch Blackwell attorney Meg Pekarske.
Another difference between home health and hospice is the dollar amounts. The payment levels for home health in the audits are lower per.
Hospice claims in OIG reports can range from $ 6 million to as much as $ 40 million.
“What we see in the home health field is less than $ 5 million,” Nowicki said. “OIG takes 100 requirements, randomly selected, evaluates them, arrives at an error rate and extrapolates it. But the end result has historically been significantly lower than what the hospice industry has encountered.”
The review process is not complaint-driven, Nowicki said. OIG does not go for specific providers, but instead for the industry itself.
“They are not looking at the provider, they are just looking at the claim data,” Nowicki said. “From that, red flags are identified, and they would never tell what the exact red flags are. But that’s how they develop this pool of potential home health agencies to audit, and based on that, they choose a certain number to go ahead and audit. “
Home health authorities should be aware that the reviews are taking place now, said Husch Blackwell Associate Erin Burns.
But it is likely that the results of these revisions will not be clear until much later.
“We are unlikely to see any final reports published until next year because the OIG audit process is quite lengthy,” Burns said. “When they come out, take a look, see what kind of things they deny, and consider whether these are points you should look at for your own agency. There may be an internal review or a strengthening of your compliance with these special questions that may be worth your time. “
Patrick Filbin
Patrick Filbin is a reporter for HHCN. Prior to joining the Aging Media Network, he was a reporter for the Chattanooga Times Free Press and a reporter for the Gillette News Record in Wyoming.
