Be Prepared: Audit Activity on the Increase

Locally, regionally and across the nation, home care agencies are reporting increased federal scrutiny.  Every agency should be especially attentive to regulatory compliance.

The Boston Office of the HHS Inspector General is visiting many agencies across New England to conduct an audit of OASIS processes, with a focus on proper and timely submission of the OASIS to the state. They are looking closely at evidence of the OASIS transmission to the State before the submission of the claim, as well as at each agency’s process to review “fatal errors” and validation reports. We believe as many as 70 agencies may ultimately be asked for records.  We have not heard of any results or payment penalties as yet as a result of these audits.

Agencies also report that as a result of the submission of their Medicare Provider Enrollment Application (CMS 855a), federal inspectors are visiting on site to verify – often with camera’s – that the physical address reported on the form is operational.

Finally, it appears the ZPIC – Zone Program Integrity Contractors – are moving into home health. Unlike RACs which just look at  overpayment issues, the ZPICs are tasked with assisting HHS in discovering fraudulent practices.  A fairly detailed legal explanation of the roles of these federal contractors can be found here.

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Author: Pat Kelleher

Pat Kelleher is Executive Director of the Home Care Alliance of Massachusetts.

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