OIG releases home health compliance plan
The Office of Inspector General released its model compliance plan for home care agencies, OIG's Compliance Program Guidance for Home Health Agencies, on Aug. 4. The guidelines follow the OIG's previously issued model programs for hospitals and laboratories. The use of an internal, voluntary compliance program is one of the best ways to prevent retroactive claim denials, cost report overpayments, and fraud by agency principals and employees, the guidelines say.
An important component of the home health guidelines is the list of "risk areas" that are of special concern to the OIG. The guidance suggests that any compliance effort should focus on these risk areas, because OIG studies and investigations have demonstrated that these areas present a high risk of noncompliance within a home health agency. The OIG sets forth 31 such areas, including billing for non-homebound patients; billing for unallowable costs of home care coordination; patient abandonment; discriminatory admission and discharge of patients; and duplication of services provided by assisted living facilities.
Home health experts, such as attorney Elizabeth Hogue of Burtonsville, MD, are urging agencies to develop and implement compliance programs, even though compliance is still voluntary. Hogue says implementing a compliance program is "urgent" now that the Health Care Financing Administration has said the soon-to-be-released Conditions of Participation will require compliance programs for participation in the Medicare program.
The OIG's model home health guidance program is available on the OIG Web site at http:// www.hhs.gov/progorg/oig.
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