Who says you don't need a compliance program?
An informal one can help you fight false charges
Because of Home Health and Hospice Care's structure for internal investigations, government agents were unable to prove any wrongdoing against the nonprofit agency of Goldsboro, NC.
Although Home Health and Hospice did not have a corporate compliance plan at the time, its program of checks and balances amounted to the same thing, says agency president Beverly Withrow, who credits the system with helping to fend off the government's false accusations.
Now, says Withrow, the agency is "involved in developing a compliance plan, and it will be in place shortly. The controls were there back then," she notes, "but they weren't formalized into a compliance plan. I think that's one of the reasons we were so sure we had not committed any fraud and abuse."
The agency, which serves 5,000 mostly rural patients in eastern North Carolina with 1,300 employees in eight branch offices, was accused of falsifying patient records and of billing Medicare and Medicaid for services not rendered. It took more than two years, but Home Health and Hospice eventually proved its innocence.
What helped was thorough documentation by administrators and staff, a practice that had become part of the corporate culture at Home Health and Hospice.
"We have meetings to review each other's bills," Withrow explains. "We go through a series of checks. If 10 visits were ordered by a doctor and 11 show up on the computer printout, then we've got a problem. We make sure that we have documentation to support that bill."
Home Health and Hospice also has developed a system of computerized logs for all doctors' orders, signed and verbal.
"You have 30 days to get a doctor to sign a plan of care," says Withrow, and our computers tell us if we're getting close to the deadline. We also have logs for verbal orders, to make sure they're done in the right time frame. We follow the doctors' orders. Controls are in place to make sure we do what we are supposed to."
Another area of self-protection the agency employs is a standard review of time sheets by branch administrators. "If we find any discrepancy indicating a visit was claimed that wasn't made, the employee is dismissed immediately, no exceptions," Withrow says.
Also standard procedure at Home Health and Hospice is an exit interview of all employees who are leaving, no matter what the reasons. "We ask them if they know of any examples of patient care being compromised or any cases of fraud and abuse. We have them sign a document stating yes or no. If they say `yes,' then we investigate."
You have reached your article limit for the month. Subscribe now to access this article plus other member-only content.
- Award-winning Medical Content
- Latest Advances & Development in Medicine
- Unbiased Content