Tag Archives: quality assurance

The value of a Mock Audit: Why home health agencies need to do this


It may be the season for goblins and gremlins, but in an era of unprecedented regulatory scrutiny for the home health field, it’s the glitches home health agencies really need to worry about.
solutions-october-main-artErrors, oversights, and inconsistencies are the hobgoblins of the home health industry, carrying high price tags in the form of claims denials – or, even more frightening, fraud investigations and hefty fines.
And, to frame things in the spirit of the season, the  scary shadow of scrutiny is looming larger.
The future of home health is filled with quality improvement requirements that have not yet been fully determined to be either tricks or treats, but home health professionals know they’re coming, sooner or later. From value-based purchasing to pre-claim reviews and a proposed new Condition of Participation for Medicare, agencies are feeling the squeeze to reduce errors and improve performance.
There’s pressure to become faster as well as better. While the Centers for Medicare and Medicaid Services has temporarily delayed rollouts of pre-claim reviews to give agencies more time to prepare, home health experts agree, by and large, that the eventual implementation will force agencies to speed up as well as fine-tune their processes.

Let’s go glitch hunting

This season, Home Health Solutions owner and president J’non Griffin recommends agencies who are serious about success take a broom, figuratively speaking, to the cobwebs and shine a light into every dark nook and cranny, to ferret out the vulnerabilities in the operation and take corrective action.
“Smart agencies are doing everything they can right now to mitigate risk,” J’non says. “They’re honing in on the quality of their documentation, reviewing clinical notes made by nurses and therapists, prioritizing internal audits and quality reviews, and following up with extra training measures to address any shortfalls.”
Done well, self-assessment takes extra time, and for an agency already struggling under clinical and operational demands, creating the time for self-evaluation can seem like an overwhelming task. It’s hard to remain objective and easy to overlook crucial details that surveyors won’t miss.
Many agencies are finding the solution is to rely on outside firms to provide the thorough and objective assessment needed to identify compliance risks and provide a plan of remedy.

What does a Mock Audit entail?

From identifying expired items in an agency’s supply closet to revealing inaccuracies in its personnel files, a Mock Audit can be a comprehensive tool for determining exactly where an agency is headed for trouble.
It’s conducted exactly as surveyors would conduct the real thing; once scheduled, there’s no advance notice given to staff.
A team spends 1-3 days on site, depending on the size of the agency being audited, with some team members remaining in the office to audit charts and personnel files while other team members conduct home visits in all disciplines.
An exit interview concludes the process, and the findings are shared with the administrator along with recommendations for improvement so that a plan of correction may be implemented. Education tailored to address specific deficiencies can be arranged.
“A Mock Audit gives the agency staff an opportunity to practice for the real thing so that they will have an idea of the survey process, whether it be state Survey or advanced accreditation,” says Heather Calhoun, Director of Special Appeals and Project Management at HHS.
She recommends agencies schedule an annual Mock Audit to help control compliance risks.
“There’s no better way for an agency to determine areas of weakness and potential risk,” Heather says.
Jason Lewallen, Director of Sales and Marketing at HHS, agrees.
“With the rapid pace of regulatory change, agencies face an uphill battle when preparing for a survey,” Jason says. “This industry is fortunate that there are programs in place that can minimize the risk of penalty before the surveyor arrives.”
Findings can result in financial gain to agencies, because audits often identify specific areas of improper documentation that result in claims denials.
“Mock Audits offer agencies the opportunity to fix errors before the organization is negatively affected by claims denials as well as accreditation or state Survey,” Jason says.
The cost of the audit, like its duration, depends on the size of the agency and a few other variables.  Give HHS a call today to discuss how a Mock Audit can help shore up your operation, and put your agency on the road to success this fall.
   

Think like an auditor

imageSeven times on a single day last week, Home Health Solutions Director of Appeals and Special Projects Heather Calhoun opened a case file and looked for proof of medical necessity.
Six of those seven times, she couldn’t find the proof she needed anywhere in the file before her.
“This is without question the No. 1 mistake I see agencies making in their day-to-day documentation, and the ramifications are enormous,” Heather says. “Without evidence that it’s needed, any care provided to a patient is not considered medically necessary and the agency may not be reimbursed for it.”
As home health agencies scramble to shore up the quality of their documentation practices under this month’s new wave of Centers for Medicare and Medicaid Services regulations, Heather and other HHS team leaders are working with agencies across the country.
Their goal is to teach home health care professionals how to think more like auditors — a skill that could be worth many thousands of dollars to an agency’s operational costs by preventing claims denials of specific services, visits or entire home health episodes of treatment.
“Documentation is an integral piece of the regulatory compliance required for agencies to succeed in today’s home health market,” HHS Owner J’non Griffin says. “We are working with agencies of all sizes to help them develop quality initiatives for meeting their regulatory burden.”

What auditors look for

To stand up to scrutiny, an agency’s documentation must be thorough. It will need to establish cause and intent for each aspect of care. That means agencies must record their delivery of patient care in clear and brief detail, beginning with the initial referral by a physician.
It isn’t enough just to note each pill, each dressing and each service provided to the patient; documentation must also show a comprehensive care plan coordinated among caregivers, with care goals specific to the patient.
But many agencies aren’t meeting all those requirements. Staffs busy with the delivery of patient care can get distracted from properly completing files — and HHS team members find that some of the same errors, omissions and inconsistencies show up routinely in the records of agencies of all sizes.

“Proper documentation is imperative for agencies,”  HHS Quality Assurance Manager Holly Kolitz says.  Even with time constraints and many competing demands,  agencies will need self-policing to  avoid costly errors and make sure documentation makes the grade.

 

Red Flag Checklist

     The HHS team has compiled the following checklist of some of the most common red flags almost guaranteed to catch the attention of auditors:
INCOMPLETE DOCUMENTATION:
— Missing physician orders
(Agencies need physician orders for each service, medication and treatment, including each change made to a patient’s medicine or treatment.)
— No evidence face-to-face physician requirement met
— No evidence of coordination of services
— No evidence of routine re-evaluation of patient care needs
— No explanation included for missed visits
— No documentation showing the physician was notified of a missed visit and why
ERRORS
– Careless mistakes due to lack of adequate proofreading 
INCONSISTENCIES: 
– OASIS, clinical notes, progress summaries, etc. fail to align, or in some cases even directly contradict each other.
— Clinicians provide conflicting information in their reports

“If a wound starts out being identified as one type of wound at the beginning of treatment, but is repeatedly identified in later documents as a different type of wound, auditors are certainly going to notice,” Holly says. “The legitimate question to be raised is whether we even know what kind of wound we’re dealing with.”
Agencies must provide documentation showing the initial diagnosis was changed or maintain uniformity throughout the treatment records, cross-checking to make certain later records support the wound identification in OASIS.
One of the most common mistakes Heather sees agencies make involves discrepancies in reporting between nurses and therapists.  A nurse, for example, may provide a highly functional score for a patient, because the nurse isn’t necessarily evaluating the same criteria as a  therapist. When a therapist evaluates the quality of the same patient’s gait,  stride or ease of transition from chair to walker, and reports lower functionality, the resulting discrepancy can become a red flag.

“Sometimes, it’s the simple mistakes that bog things down,” Holly adds. “Agencies can sometimes miss the obvious in recording details, and the results can create real issues.”
From copying a medical code wrong to identifying the wrong site for an injection or mistakenly substituting “right” for “left” on a record of a limb amputation, careless errors can sometimes cost an agency thousands of dollars.
The HHS team strongly recommends self-evaluation  in agencies, with frequent reviews of all documentation for accuracy.

One other area likely to generate red flags in an agency’s documentation is a lack of specificity. Tomorrow’s post will focus on strategies to better capture the important details needed for quality documentation.

Wednesday: The Mechanics Of Specificity 

Did you see our companion post on the four elements of quality documentation?  Read it here