Home Health Care Enforcement: Total Compliance Review

January 7, 2019 Alerts and Newsletters

Both the federal Office of Inspector General and the state Attorney General's Medicaid Fraud Division have made home health care an enforcement priority. Whether it be the "face-to-face" certification requirements or third party liability clawbacks, home health agencies are at continued risk for overpayment audits, recoupments and enforcement actions. Every home health agency should identify and correct potential issues before they result in a focused audit.

Verrill Dana LLP has many years of experience representing home health agencies subject to Medicare and Medicaid audits and investigations. Working in conjunction with an experienced home care compliance professional with extensive documentation, coding and billing experience, Verrill Dana offers to review the documentation and coding processes to determine the HHA's compliance with federal and state regulatory requirements, and to offer corrective actions if necessary.

To assess the documentation flow from the initial patient referral through the various services rendered by HHA staff to the billing of those services, Verrill Dana and the compliance consultant would meet with the HHA's senior management and clinical directors. Following the initial meeting and review of the documentation and billing process, the compliance consultant would review a sample of patient files (including medical records and billing information) to assess the sufficiency of the documentation and appropriateness of the coding and billing. Thereafter, the attorneys and consultant would meet with HHA management and provide an assessment of the agency's compliance. Following that meeting, Verrill Dana would provide written recommendations regarding any issues that may need to be addressed.

Based on past legal/compliance audits conducted by Verrill Dana, it is often found that the revenue opportunities identified during the audit outweigh the costs.

Please contact Paul Shaw or another member of Verrill Dana's nationally-recognized Health Care Group if you have any questions regarding your agency's practices or would like assistance in identifying and correcting potential issues.

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