The home health industry should keep its collective eye on the U.S. Department of Health & Human Services Office of the Inspector General’s (HHS-OIG) recent audits on the hospice industry, because it soon could be next.
As the home health space continues to grow, federal oversight and the scrutiny attached to the industry have grown with it.
Experts at Husch Blackwell have followed this trend through the hospice industry, and have gleaned knowledge from that.
“As we have been following and reporting on those hospice audits, the OIG has been looking at the home health space as well,” Bryan Nowicki said this week on a podcast episode of Hospice Insights. “They’re very similar in overall structure with what we have been working on with hospice. They’re looking for certain kinds of errors that they’ve identified as being recurring or ‘top of mind’ in the home health field.”
When the OIG first began its hospice audits in 2021, the office was looking for things like whether beneficiaries met the definition of being confined to a home; whether they were truly in need of skilled services; whether the OASIS information was being submitted in a timely fashion; and whether services were properly documented.
Those were the four priorities being reviewed by the OIG, Nowicki said. Now the OIG is cranking up those efforts and focus areas, this time for home health agencies.
“Frankly, those are pretty recurring issues in home health,” Nowicki said. “We would expect more of the same, but [the audit process] is going to be guided by what they actually find. Audits are happening now and the OIG’s goal is to begin issuing final audit reports and publishing them on their website in 2023.”
Unlike many audits, results from the OIG audits are made public, which creates even more anxiety from the industry, according to Husch Blackwell attorney Meg Pekarske.
Another difference between home health and hospice is the dollar amounts. Payment levels for home health in the audits are lower on a per-claim basis.
Hospice claims in OIG reports could range from $6 million to as much as $40 million.
“What we see in the home health area is less than $5 million,” Nowicki said. “The OIG takes 100 claims, randomly selected, evaluates them, arrives at an error rate and extrapolates it. But the end result number, historically, has been significantly lower than what the hospice industry has encountered.”
The audit process is not complaint-driven, Nowicki said. The OIG isn’t going after specific providers, but instead after the industry itself.
“They don’t look at the provider, they just look at the claims data,” Nowicki said. “From that, red flags are identified and they’d never tell what the exact red flags are. But that’s how they develop this pool of potential home health agencies to audit and then, from that, they select a certain number to go ahead and audit.”
Home health agencies should be aware the audits are happening now, Husch Blackwell Associate Erin Burns said.
But it’s likely that results from these audits won’t be clear until much later dates.
“We probably won’t see any sort of final reports published until next year because the OIG audit process is pretty long,” Burns said. “Once those come out, take a look, see what kinds of things they’re denying, then consider whether those are points that you should look at for your own agency. There may be some internal review, or beefing up your compliance on those particular issues, that might be worth your time.”
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