Home Health and Hospice Compliance Focus
Home Health and Hospice in the Crosshairs
Governmental Enforcement Actions Against Post Acute Care Providers
Home health agencies and hospices are seeing a rapidly accelerating level of scrutiny by federal and state regulatory agencies. Post acute providers need to take note of increased enforcement action and examine their level of readiness to undergo audit and review. These organizations need to brush off their compliance and audit programs and take steps necessary to avoid the disruption and financial exposure that inevitably occurs when the government discovers a problem.
Compliance programs should create a systematic process to identify areas of risk that are specific to the type of provider and the specific nature of their operations. A good place for providers to begin the risk identification process is to review OIG annual work plans, recent enforcement actions, newly enacted legislation and other external indications of areas of concern to regulators.
HHS officials have publicly stated that home health and hospices are areas of concern. Sources of increased scrutiny include state survey agencies, CMS program integrity review organizations, the Office of Inspector General, Department of Justice and a variety of other agencies. Regulators are widely using statistical analysis to identify potential outlier billings that may require further review. Some reviews arise when whistleblowers such as employees or others bring qui tam actions or make complaints to government agencies.
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