Medicare Blog

what could have medicare people come in to audit home care business

by Dr. Laron O'Kon V Published 2 years ago Updated 1 year ago
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The fact is that there is some item you have claimed as a Medicare provider or the amount of claims Medicare has paid in a certain category that has caused you or your practice to be audited. Having too many claims for level five CPT codes might, for example, cause you to be audited.

Full Answer

Can I avoid a Medicare audit?

Furthermore, if the audit uncovers any actions deemed fraudulent, your Medicare Administrative Contractor (MAC) will refer your case to the appropriate agency for further investigation. While you might not be able to avoid an audit, you can make sure you’re totally prepared to face one.

How should the audit of excellent home care be adjusted?

The audit should be adjusted to eliminate doubtful disallowances and provide Excellent Home Care with the opportunity to continue to provide excellent home care. Attached are rebuttals to the individual claims. You will note that not every claim is contested. The Provider concurred with some of the clisallowances made by the auditors.

Did excellent home care services comply with Medicare requirements?

Excellent Home Care Services, LLC, did notfully comply with Medicare requirements for billing home Ilea/tit services, resulting in ove1payments ofat least $7.5 million over 2 years. WHY WE DID TIDS REVIEW This review is part of a series of reviews of home health agencies (HHAs).

How does the senior care-check audit work?

Using the Senior Care-Check Audit app located on their smartphones, Auditors assess 150 items related to your senior’s well-being: Senior Observations, Safety, Comfort, Cleanliness, Supplies, Maintenance, and Caregiver Observations. Immediately following the audit, the Penrose Check-In Report, including findings and suggestions, is emailed to you.

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What triggers a Medicare audit?

What Triggers a Medicare Audit? A key factor that often triggers an audit is claiming reimbursement for a higher than usual frequency of services over a period of time compared to other health professionals who provide similar services.

What will the Medicare auditor check during the audit?

Medicaid and Medicare auditors are briefed to scrutinize healthcare professionals on procedures for prescribing pain medications and narcotics to beneficiaries. So, brush up on California's opioid regulations and insurance coverage rules for pain management on Medicare, as well as others.

Who gets audited by Medicare?

For example, the Medicare program is required to make random audits of 10% of all Medicare providers on an ongoing basis. An audit or investigation can result from complaints by patients about the quality or appropriateness of the care they received, or how they were billed for their care.

What are the types of Medicare audits?

There are mainly three types of audits — Recovery Audit Contractor (RAC) audits, Certified Error Rate Testing (CERT) audits and Probe audits. Mistakes in medical documentation, coding and billing can rouse Medicare's suspicion during audits, which can lead to claim denials.

What happens when Medicare audits?

After the provider submits the requested universes, auditors will assess the data provided and determine whether any other information is necessary. This phase will last six weeks. Field work by auditors - Auditors will conduct webinar audits and evaluate sample data from the submitted universes.

How far back can Medicare audit go?

Medicare RACs perform audit and recovery activities on a postpayment basis, and claims are reviewable up to three years from the date the claim was filed.

How long does a Medicare audit take?

After the provider is “targeted” using data analytics, the MAC performs up to three rounds of "probe and Educate." Each round takes about 90 days—30 days for MAC to review the claims, a few days to schedule an educational call, 45 days for providers to show improvement—and is centered around a one-on-one educational ...

What happens if you fail a CMS audit?

Civil monetary penalties (CMPs) of up to $1,000,000 as adjusted annually2 may be imposed on reporting entities if they fail to report information in a timely, accurate, or complete manner.

What is a Medicare OIG audit?

Under this authority, OIG conducts audits of internal CMS activities, as well as activities performed by CMS grantees and contractors. These audits are intended to provide independent assessments of CMS programs and operations and to help promote economy and efficiency.

What triggers a RAC audit?

RAC audits are not one-time or intermittent reviews and can be triggered by anything from an innocent documentation error to outright fraud. They are part of a systematic and concurrent operating process that ensures compliance with Medicare's clinical payment criteria, documentation and billing requirements.

What is the purpose of Medicare audits?

The Medicare Fee for Service (FFS) Recovery Audit Program's mission is to identify and correct Medicare improper payments through the efficient detection and collection of overpayments made on claims of health care services provided to Medicare beneficiaries, and the identification of underpayments to providers so that ...

What is audit protocol?

Audit protocols assist the regulated community in developing programs at individual facilities to evaluate their compliance with environmental requirements under federal law. The protocols are intended solely as guidance in this effort.

Why do UPIC employees show up at home health providers?

Other times, UPIC employees might show up at a home health provider’s door — announced or unannounced — to ensure the business is operational and request records.

What to do if a home health agency is uncomfortable?

If a home health agency is still uncomfortable, it can request a CMS contact to ensure the representative is legitimate.

What is CMS's priority?

Reducing improper payments has been a priority for CMS in recent years, with the agency taking several measures to help curb fraudulent or sloppy claims submissions. Efforts, for example, include the 2016 Pre-Claim Review Demonstration and the upcoming Review Choice Demonstration.

How much did home health improper payments decrease in 2018?

Additionally, home health improper payment rates decreased from 58.95% in 2015 to 17.61% in 2018.

Where was the Chicago audit held?

Long explained the audit process and touched on common investigation catalysts during the event, held in Itasca, Illinois, a suburb of Chicago.

Can a patient be ineligible for home health?

Per CMS’s criteria, that patient would be ineligible for the home health benefit. To receive home health services, patients must be confined to their home and require skilled care. They must also be under the care of a physician, with whom they’ve had a face-to-face encounter, and have a plan of care established.

Does AdvanceMed cover the Midwest?

While AdvanceMed serves the Midwest, other regions of the country are covered by different UPICs. In the West — which also includes Alaska and Hawaii — and Southwest, it’s Maryland-based Qlarant Integrity Solutions. Meanwhile, CMS contracts Florida-based SafeGuard Services to cover the Northeast and Southeast.

What is the biggest problem with Medicare audits?

The biggest problem concerning audits, without question, is physician documentation being deemed insufficient. Recent changes to the Medicare Program Integrity Manual, which guides audit contractors, have reflected what we are noticing in these audits. The Centers for Medicare & Medicaid Services (CMS) wants to see that the physician documentation specifically addresses the criteria listed in the Indications and Limitations of Coverage section of the Local Coverage Determinations, and that it is documented in their notes as well as in the normal format that they document their own services. This seems reasonable, in theory, except for the fact that CMS does not fund the DME MACs to educate physicians and the Part B MACs are not funded to educate physicians on DME policies. So physicians do not know what they are supposed to document—it’s up to you to educate them.

How to audit a physician?

Lack of physician documentation complicates audits. Here are some points you should make to the physicians in your referral network: 1 CMS doesn’t fund physician education, so it’s up to you to educate them. Help physicians understand the challenges you face and ask for their help. 2 Encourage cooperation from physicians by touting the term “compliance.” It’s not an option for physicians to comply, it’s the law. 3 Emphasize that it’s not your requirement to provide documentation, but Medicare’s, and in order for you to be in compliance you need the documentation. 4 Physicians may become the target of an audit when their documentation isn’t deemed sufficient, so market yourself as a company that will help them to comply. 5 Point out that the current environment of intense regulatory oversight is affecting a wide variety of health-care providers, including physicians.

How to encourage cooperation from physicians?

Encourage cooperation from physicians by touting the term “compliance.”. It’s not an option for physicians to comply, it’s the law. Emphasize that it’s not your requirement to provide documentation, but Medicare’s, and in order for you to be in compliance you need the documentation.

What is the importance of holding your patients accountable?

If you get the patients involved in their treatment and care, and educate them under what circumstances Medicare will cover the equipment that was ordered for them, it helps them understand what is needed to get their claim reimbursed accordingly so they are not liable. If you explain to patients that their physician has failed to comply with the request for documentation, and as a result they may be responsible for payment of the services, they will naturally be motivated to contact their physician.

Is a medical necessity order part of the medical record?

However, if you have this information on your order, Medicare is clear that the order is not part of the “clinical record” for purposes of an audit.

Does CMS fund DME MACs?

This seems reasonable, in theory, except for the fact that CMS does not fund the DME MACs to educate physicians and the Part B MACs are not funded to educate physicians on DME policies. So physicians do not know what they are supposed to document—it’s up to you to educate them.

Can a physician be audited?

Physicians may become the target of an audit when their documentation isn’t deemed sufficient, so market yourself as a company that will help them to comply. Point out that the current environment of intense regulatory oversight is affecting a wide variety of health-care providers, including physicians.

Preparing For Medicare Audits Before They Happen

When implementing any care management program, you’ll want to review the CMS billing rules to ensure compliance.

Commonly Audited Areas

Having a care coordination software that automates much of the documentation and time logging required, and offers intuitive reporting features, can help ease the audit process.

What To Do If You Get Audited

Don’t panic. Upon hearing you’re being audited, many practices begin to worry.

How Care Management Software Helps Helps The Audit Process

You may have gathered by now that thorough record keeping and reporting goes a long way during the audit process.

What does a Recovery Audit Contractor (RAC) do?

RAC's review claims on a post-payment basis. The RAC's detect and correct past improper payments so that CMS and Carriers, FIs, and MACs can implement actions that will prevent future improper payments.

What Topics do RAC's Review?

Stay in the know on proposed and approved topics that RAC's are able to review. These topics will be updated monthly on the RAC reviews topic page and include:

What is Medicare audit?

The Centers for Medicare and Medicaid Services (CMS) has multiple tools at its disposal for audits, all of which are intended to monitor the accuracy of these Medicare fee-for-service (FFS) claims and to detect and prevent fraud and abuse. Audits can occur prior to Medicare payment as well as after payments have been received—even years later.

What is the goal of RAC audits?

These contractors’ goals are to find and correct inap-propriate FFS payments and to prevent future fraud-ulent claims. Because RAC auditors earn incentives that can range from 9 to 12 ½ percent of recovered payments, they are motivated to find every possible error in a record, making RAC audits most worrisome.

Is Medicare auditing your business?

If your medical supply business hasn’t been audited, the chances are quite good that it will be. Failure to respond quickly and appropriately can be devastating to your business, but it’s possible to manage the audit challenge.

How many struts of care did Medicare not bill?

The Agency did not comply with Medicare billing requirements for 96 ofthe 124 struts-of-care (156 of the 555 home health claims) we reviewed. Specifically, the 96 starts-of-care had billing enors resulting in net overpayments of $497,608. The Agency inconectly billed Medicare for

What is inconectly billed for Medicare?

(1) some beneficiaries who were not homebound, (2) some beneficiaries who did not require skilled services, and (3) some services for which the documentation from the ce1tifying physician was missing or insufficient to support the services.

What is the purpose of the HHS?

reduce waste, abuse, and mismanagement and promote economy and efficiency tlu·oughout HHS.

What is OAS in HHS?

The Office of Audit Services (OAS) provides auditing services for HHS, either by conducting audits with its own audit resources or by overseeing audit work done by others. Audits examine the perfmmance of HHS programs and/or its grantees and contractors in carrying out their respective responsibilities and are intended to provide independent assessments ofHHS programs and operations. These assessments help

Can a patient be considered skilled nursing?

However, in some cases, the condition ofthe patient may cause a service that would ordinarily be considered unskilled to be considered a skilled nursing service. This would occur when the patient's condition is such that the service can be safely and effectively provided only by a nurse.

What is an appeal in Medicare?

Appeal—An appeal is the action you can take if you disagree with a coverage or payment decision made by Medicare, your Medicare health plan, or your Medicare Prescription Drug Plan. You can appeal if Medicare or your plan denies one of these:

How many days can you be on Medicare?

Fewer than 7 days each week. ■ Daily for less than 8 hours each day for up to 21 days. In some cases, Medicare may extend the three week limit if your

What is the ABN for home health?

The home health agency must give you a notice called the “Advance Beneficiary Notice of Noncoverage” (ABN) in these situations. See the next page.

What happens when home health services end?

When all of your covered home health services are ending, you may have the right to a fast appeal if you think these services are ending too soon. During a fast appeal, an independent reviewer called a Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO) looks at your case and decides if you need your home health services to continue.

What is homemaker service?

Homemaker services, like shopping, cleaning, and laundry Custodial or personal care like bathing, dressing, and using the bathroom when this is the only care you need

How many days can you have home health care?

care. You can have more than one 30-day period of care. Payment for each 30-day period is based on your condition and care needs. Getting treatment from a home health agency that’s Medicare-certified can reduce your out-of-pocket costs. A Medicare-certified home health

Why is home health important?

In general, the goal of home health care is to provide treatment for an illness or injury. Where possible, home health care helps you get better, regain your independence, and become as self-sucient as possible. Home health care may also help you maintain your current condition or level of function, or to slow decline.

What is home healthcare?

Home healthcare also referred to as formal or skilled care, is the support and care services that healthcare professionals provide at the patient’s own home. These care services include respiratory therapy, home infusion therapy, rehabilitation services, telehealth, unskilled home care, and other services.

Why is it important to take a detailed inventory of your home care business?

While all businesses struggle in one way or another , it’s important to take a detailed and honest inventory of your performance. Only by doing this can you begin the road to improvement and create a growing, healthy home care business. If you’re making one or more of these mistakes, take the necessary steps to solve the problem and prevent the negative impact these issues could have on your client pool and reputation.

What is home care pulse?

We’re Home Care Pulse, a leading provider of experience management & surveys, caregiver/CNA training, and online reputation management.

Do companies send out monthly bills?

Some companies send out a weekly bill, but some clients prefer monthly billing since it’s easier to keeping track of payments. Keep clients in mind when planning your billing schedule.

Is knowingmore.com merged with homecarepulse?

We’re bringing things together! The knowingmore.com website has merged with homecarepulse.com and you’ve been redirected. Welcome to the new site!

Do home care agencies work hard?

While most home care agencies work extremely hard to provide great care to every client, there’s still a great deal that can be done to improve care and ensure even better experiences for clients.

Can a caregiver call in sick?

It’s not uncommon for caregivers to call in sick to the office, but the office doesn’t call the clients or send a replacement. This is a communication problem that could cause astronomical problems for your clients and your home care business.

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