OIG Releases 2013 Work Plan for Home Health

The Health and Human Services Office of Inspector General (OIG) annually issues its Work Plan for the following year.

The OIG Work Plan for Fiscal Year 2012 provides descriptions of activities that OIG plans to initiate or continue with respect to HHS programs and operations in fiscal year 2012. Nine home health specific projects are planned or currently underway. The Plan identifies targeted activities under both the Medicare and Medicaid programs.

Medicare Home Health Projects include:

  • States’ Survey and Certification of Home Health Agencies: Timeliness, Outcomes, Followup, and Medicare Oversight (New): Review the timeliness of home health agency (HHA) standard and complaint surveys conducted by State Survey Agencies and Accreditation Organizations, the outcomes of those surveys, and the nature and follow-up of complaints against HHAs.
  • Medicare’s Oversight of Home Health Agencies’ Patient Outcome and Assessment Data (Work in Progress):Re view CMS’s oversight of Outcome and Assessment Information Set (OASIS) data submitted by Medicare-certified HHAs, including CMS’s process for ensuring that HHAs submit accurate and complete OASIS data.
  • Missing or Incorrect Patient Outcome and Assessment Data (New):Review home health agencies OASIS data to identify payments for episodes for which OASIS data were not submitted or for which the billing code on the claim is inconsistent with OASIS data.
  • Questionable Billing Characteristics of Home Health Services (New):Review home health claims to identify home health agencies that exhibited questionable billing in 2010. Questionable billing refers to claims that exhibit certain characteristics that may indicate potential fraud. HHAs that had a high percentage of claims that meet at least one of the questionable billing characteristics will be reviewed.
  • Home Health Agency Claims’ Compliance with Coverage and Coding Requirements (Work in Progress): Review Medicare claims submitted by HHAs to determine the extent to which the claims meet Medicare coverage requirements and the accuracy of resource group codes submitted for Medicare home health claims in 2008 and identify characteristics of miscoding.
  • Medicare Administrative Contractors’ Oversight of Home Health Agency Claims (New): Review fraud and abuse prevention and services performed by the home health benefit MACs.
  • Wage Indexes Used To Calculate Home Health Payments (New):Determine whether Medicare home health payments were calculated using incorrect wage indexes and evaluate the adequacy of controls to prevent such inaccuracies.
  • Home Health Prospective Payment System Requirements (New): Review compliance with various aspects of the home health PPS, including the documentation required in support of confined to home and medical necessity of the claims paid by Medicare.
  • Home Health Agency Trends in Revenues and Expenses (New): Review cost report data to analyze HHA revenue and expense trends under the home health PPS to determine whether the payment methodology should be adjusted including examination of various Medicare revenue and expense trends for freestanding and hospital-based HHAs.

Cross-Provider Projects

There are also a number of work plan projects that will impact both home health and hospice providers including:

  • Medicare Claims Review (Restart): Review of Medicare Part A and Part B claims submitted by error-prone providers to determine their validity, project our results to each provider’s population of claims, and recommend that CMS request refunds on projected overpayments.
  • Variation in Coverage of Services and Medicare Expenditures Due to Local
    Coverage Determination: Review variation in Medicare spending and coverage of services due to LCDs and the evidence Medicare contractors use to develop LCDs and assess CMS’s monitoring and oversight of LCDs.
  • Provider Education and Training: Medicare-Affiliated Contractors’ Progressive
    Correction Action: Review the progressive corrective action (PCA) provider education and training programs conducted by Medicare-affiliated contractors to determine whether such programs have reduced billing and payment error rates and noncompliance.



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