Posted Thursday, August 11, 2022
The pandemic saw a decrease in audits for home health agencies from the U.S. Department of Health & Human Services, but that could change very soon.
“Having a very healthy, robust compliance program that really challenges the health of a home health agency internally is a good way to be ready for when an outside entity, like the government, does the same,” Bryan Nowicki, a partner at Husch Blackwell, told HHCN.
Home health agencies should be at a place where they aren’t just prepared for audits, but also expect them.
“Don’t be surprised if and when you get an audit,” Husch Blackwell Associate Erin Burns told HHCN. “It’s likely going to happen, and knowing that should help you be more prepared in the long run.”
Historically, audits done by OIG entailed the office taking 100 claims at random, evaluating those claims and then coming to an error rate. OIG will then extrapolate that error rate and assess it over the industry.
Other audits — like the ones done by unified program integrity contractors (UPICs) hired by the U.S. Centers for Medicare & Medicaid Services (CMS) — are used to investigate home health agencies for potential fraud.
“We have seen an uptick in UPIC activity across the board for home health this year and I think that relates, in part, to the government relaxing some of the COVID restrictions,” Nowicki said. “I think the audits will focus on the time periods when COVID was an issue and I think that’s something home health agencies will have to address.”
“Documentation is key in compliance programs,” Burns said. “Hopefully they are keeping up with their compliance program, documenting their efforts, doing internal reviews on policies and procedures and making sure those mirror and support their internal processes.”
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