Why Home Health Insiders Expect Uptick In Audits, Inquiries From Federal Watchdogs

Home Health Care News

Audits from the U.S. Department of Health & Human Services’ Office of Inspector General (HHS-OIG) can often catch home health agencies by surprise.

And after a slower audit period during the COVID-19 pandemic, experts told Home Health Care News that providers should expect a ramp-up in audits over the next year.

Battling that element of surprise will be key to getting through a successful audit process.

“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.”

“The audit process itself is — as we tell our clients — a marathon, not a sprint,” Burns said.

Knowing that audits are coming is part of the battle, Burns said. But knowing what OIG or other federal agencies are looking for is another piece to the puzzle.

Historically, audits done by OIG include 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.”

Many in the industry have expected OIG audits to proliferate in home health, like they have in hospice over the last few years. The home health industry could also see an uptick in audits from OIG on provider relief funds as well, Burns said.

Generally, both audit processes will look at financial data for home health agencies, homebound statuses, OASIS compliance and other factors that impact payment.

OIG is likely going to refine what exactly they are looking for on the other side of the pandemic, Nowicki said. However, what that looks like won’t be known for another year or so.

Read Full Article