Here’s why it’s important to know who is REALLY handling your coding and billing
It may be time to take a harder look at your agency’s coding and billing practices to determine whether you’re at unnecessary risk of being charged with fraud — particularly in light of this summer’s announcement that the U.S. Health and Human Services Office of Inspector General (OIG) will launch a new probe to identify improper payment patterns.
The OIG will use data from the Centers for Medicare and Medicaid Services CERT Program (Comprehensive Error Rate Testing) to look for agencies with improper payments, honing in on any identifiable patterns to compile a list of common characteristics among agencies CMS believes were improperly paid.
Last year, CERT identified some $7 billion in improper payments among home health claims.
“This new initiative by the OIG sends a strong message to the home health industry,” said J’non Griffin, owner and president of Home Health Solutions LLC. “The period of hesitancy during the administration changeover earlier this year is ending, and we’re getting back to business as usual, with continuing scrutiny on home health for evidence of fraud or wrongdoing.”
How can agencies mitigate their risks for fraud or non-compliance?
Outsourcing services to a competent and professional firm is one of the best ways in which an agency can continue to focus on delivering quality health care instead of struggling to meet the compliance burden – but J’non cautions that outsourcing may have its own risks.
Agencies which rely on outsourcing for coding and billing should protect themselves by being especially diligent not just in vetting the reputation and credentials of the firms contracted to provide services, but in ascertaining the credentials of the employees who actually perform the outsourced work for the company, J’non said.
Questions which agencies should be asking as they seek reputable outsourcing firms include:
How many of the reviewers are clinicians?
Are employees experienced in the home health and hospice fields? How many years of experience do they have?
Are they credentialed in home health and hospice specific coding?
Are the reviewers located in this country or abroad?
Are they HIPAA trained?
Are they familiar with the U.S. Health and Human Services Office of Inspector General focus on suspected fraud? Do they understand the importance of compliance to your agency’s success?
Are they knowledgeable about CMS requirements and otherwise well prepared to protect your agency?
“These are important questions for agencies to ask – more important in the long run than pricing,” J’non said. “Agencies can’t afford the cost of shoddy work quality in such heavily scrutinized circumstances.”
The HHS Who’s Coding You Challenge
Home Health Solutions LLC has announced an industry-wide “Who’s Coding You?” challenge in an effort to take the anonymity out of the outsourcing business and reassure home health agencies about the credentials and knowledgeability of our staff.
Over the next few months, we’ll be spotlighting the names, faces and credentials of all our team members to introduce to the world the people who make up our company.
“We’re proud of the HHS team and confident in the commitment to quality our team members show every day,” J’non said. “Instead of hiding our best and important assets behind the company name, we want to show them off, creating the opportunity for agencies to get to know each one of them, and learn firsthand how committed they are to doing the right thing for the agencies we serve.”
Other OIG concerns
Other areas of concern for agencies included on the July work plan posted by the OIG include plans to evaluate Medicare Part A payments to home health agencies to determine whether claims billed to Medicare Part B for services and items were permissible and in accord with federal regulations. Certain supplies, items and services provided to inpatients are covered under Part A and should not be separately billable to Part B.
According to Section 1842 (b)(6)(F) of the Social Security Act, consolidated billing for all home health services is required while the beneficiary is under a home health plan of care authorized by a physician. The Act established a Medicare prospective payment system that pays home health agencies (HHA) for home services and covers all of their costs for furnishing services to Medicare beneficiaries. Pursuant to the home health consolidated billing requirements, the HHA that establishes a beneficiary’s home health plan of care has Medicare billing responsibility for services furnished to the beneficiary. Payment is made to the HHA whether or not the item or service was furnished by the HHA or by others by arrangement.
The OIG will review Medicare Part A payments to HHAs to determine whether claims billed to Medicare Part B for items and services were allowable and in accord with Federal regulations.
The OIG work plan also announced that it will review Medicare claims paid for telehealth services provided at distant sites that do not have corresponding claims from originating sites to determine whether those services met Medicare requirements.