Posted by: Robert Markette
March 09, 2007
Topic: New from CMS

Yesterday, the Inspector General of the Department of Health and Human Services gave testimony to the house committee on ways and means. The testimony covered a wide range of topics related to the Office of Inspector General’s duties, but one portion of his testimony is of special interest to the home health community.

The Inspector General reiterated his offices “long standing” concern with the accuracy of payments made to home health agencies.  He stated that OIG continues to believe that CMS’s failure to adjust for “substantial unallowable costs” claimed by HHAs in their cost reports has led to “inflated base rates.”

He went on to outline steps OIG will be taking to evaluate payments made to HHAs.  They plan to look at the accuracy of assessment form coding and appropriates and medical necessity of certain rehab services.  Although he did not go into specifics, this testimony raised a red flag for me.

IF OIG feels that HHAs are receiving payments based upon an inflated base rates resulting from bad data, the result of OIGs efforts may be to correct this “mistake.”  Personally, I see how HHAs are struggling to get by on what CMS pays, but OIG seems to think you are getting paid too much.  The effect of a “correction” could be a reduction in the PPS base rate.  Just one more place the government is looking at rate reductions.

Practically, knowing that OIG is going to be reviewing the accuracy of coding on assessment forms and issues related to rehab services, providers should make efforts to ensure they are doing things correctly and accurately.For those hospice providers who read this blawg, the only mention of hospice was in connection with nursing homes. It should not surprise you that OIG testified that it is continuing to review the “appropriateness of payments and care for hospice beneficiaries residing in nursing homes.”  The potential for fraud and abuse in hospice-nursing home relationships is a long standing concern of OIGs.

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