{"id":5475,"date":"2022-04-27T16:53:29","date_gmt":"2022-04-27T16:53:29","guid":{"rendered":"https:\/\/melodybenefits.com\/?p=5475"},"modified":"2023-08-24T14:35:12","modified_gmt":"2023-08-24T14:35:12","slug":"home_healthcare_audits_surveys","status":"publish","type":"post","link":"https:\/\/melodybenefits.com\/home_healthcare_audits_surveys\/","title":{"rendered":"2022 – Year of the Home Healthcare Audit?"},"content":{"rendered":"
Remember that sinking feeling you got when your teacher announced a pop quiz?<\/span><\/p>\n <\/p>\n Now multiply that a few billion times to get the stomach-knotting sensation of a home healthcare agency<\/a> audit.\u00a0 The stakes are infinitely higher \u2014 fines, criminal penalties, or <\/span>termination from Medicare and Medicaid.\u00a0<\/span><\/p>\n <\/p>\n Surveys and audits are built into the home healthcare system and can\u2019t be wished away.<\/span> To prepare agencies for the inevitable,<\/span> the <\/span>CHC<\/span><\/a> (Community Health Care Services Foundation) recently hosted a webinar called \u201cHome Care Audits – Facts & Trends.\u201d\u00a0<\/span><\/p>\n <\/p>\n (The CHC is the educational affiliate of <\/span>HCP<\/span><\/a>, the New York State Association Of Health Care Providers.)\u00a0<\/span><\/p>\n <\/p>\n The following are key takeaways from that session.<\/span><\/p>\n Presenter Patricia Tulloch, a Senior Consultant at <\/span>RBC Limited, Healthcare & Management Consultants<\/span><\/a>, said it straight: \u201c<\/span>This will be a heavy year for surveys and audits.<\/b>\u201d<\/span><\/p>\n <\/p>\n Why?<\/span><\/p>\n <\/p>\n First, she pointed to the COVID staffing shortages that agencies are experiencing. With so many aides out, it\u2019s not always possible to replace them. Disgruntled patients or families, annoyed at not getting care, then file a complaint with the DOH. And complaints always trigger investigations.<\/span><\/p>\n <\/p>\n The second reason traces Medicare and Medicaid oversight back to its roots in Washington. The <\/span>OIG<\/span><\/a> (Office of Inspector General) is a federal agency that fights Medicare and Medicaid fraud and abuse. It conducts studies and reports to Congress.\u00a0<\/span><\/p>\n <\/p>\n In its latest work plan, OIG recommends increased auditing, investigations, and inspections of all healthcare providers. OIG doesn\u2019t perform audits, but its directive sets the agenda for the state agencies that do.<\/span><\/p>\n <\/p>\n The OIG recommendation isn\u2019t arbitrary. The government has specific concerns, and it\u2019s directing state agencies to focus on those areas:<\/span><\/p>\n <\/p>\n <\/p>\n Getting into details, there are two routine investigations that New York HHAs face:<\/span><\/p>\n <\/p>\n Forewarned is always forearmed, so here\u2019s what to expect from each audit:<\/span><\/p>\n Purpose:<\/b>\u00a0<\/span><\/p>\n OMIG audits save the state money by preventing Medicaid fraud and recovering improperly spent funds. They also generate money from penalties. In 2020 alone, OMIG recovered $215 million from audits!<\/span><\/p>\n <\/p>\n OMIG audits will flag agencies for discrepancies such as<\/span><\/p>\n You can download the complete list of <\/span>LHCSA audit protocols<\/span><\/a> from OMIG\u2019s website.<\/span><\/p>\n <\/p>\n For 2022, audits will also focus on<\/span><\/p>\n <\/p>\n Process:<\/b><\/p>\n OMIG audits are thorough, long-term investigations. After setting up an initial conference call, the auditors select and review 100 clinical records from the past three years. In 2022, they\u2019ll look at 2017-2019. They also examine:<\/span><\/p>\n When they\u2019re done, the auditors conduct an exit conference summary. They give you a Preliminary OMIG Report listing all your missing documents and giving a timeframe to submit them. Then they\u2019ll review the information again and produce a Final Report.<\/span><\/p>\n <\/p>\n As mentioned above, OMIG\u2019s chief objective is to find and correct Medicaid overpayments. <\/span>If the auditors find an error in the 100 records, they extrapolate those findings and compound it by your total Medicaid billing.\u00a0<\/b><\/p>\n <\/p>\n So, for example, an agency might bill $50 million a year to Medicaid. If the OMIG auditors find a 5% error rate in their sample, they\u2019ll extrapolate 5% of $50 million. That\u2019s $2,500,000 that the agency may owe!\u00a0<\/span><\/p>\n <\/p>\n However, there is a settlement process. <\/span>It\u2019s crucial to have legal counsel throughout the audit and especially during the settlement to negotiate lower penalties.\u00a0<\/b><\/p>\n <\/p>\n Purpose:<\/b>\u00a0<\/span><\/p>\n The DOH is the government body that licenses New York\u2019s home healthcare agencies. After the initial state licensure survey, the DOH performs periodic surveys to ensure the agency follows all state and federal regulations.\u00a0<\/span><\/p>\n <\/p>\n The DOH focuses on your policies and procedures, with an emphasis this year on infection control and COVID19. <\/b>Practically speaking, they\u2019ll be looking at your:<\/span><\/p>\n <\/p>\n Process:<\/b><\/p>\n DOH surveys are unannounced, happening approximately every three years for LHCSAs. During COVID, they conducted virtual surveys, but they’re back to in-person visits.<\/span><\/p>\n <\/p>\n When the surveyors come, they’ve already done considerable remote surveillance, using data mining to access your documentation. They will check that information against reality!<\/span><\/p>\n <\/p>\n Beyond the COVID policies mentioned above, they\u2019ll request extensive documentation:<\/span><\/p>\n (To see the HCP\u2019s very helpful sample survey, <\/span>click here<\/span><\/a>.)<\/span><\/p>\n <\/p>\n Within two weeks of the survey, the Department sends you an Inspection report, identifying any deficiencies. You then have ten days to send back a written, detailed corrective action plan. The DOH reviews the plan and later comes for a follow-up visit.\u00a0<\/span><\/p>\n <\/p>\n For serious deficiencies, an agency may be fined or have to terminate its Medicaid participation.<\/span><\/p>\n <\/p>\n Countless details go into an audit, but the webinar noted some general best practices that can help you successfully pass your audits.<\/span><\/p>\n <\/p>\n <\/p>\n \u201cIt all comes down to record-keeping,\u201d says Shaya Sternhill, Melody Benefits Head Of Business Development & Sales. \u201cIf your records are in order, you can feel confident about being audited.\u201d<\/span><\/p>\n <\/p>\n That\u2019s why Melody is meticulous about tracking data. We do the work for you, sending you a monthly report on your:<\/span><\/p>\nIncreased audits and surveys<\/b><\/h3>\n
Audit and survey priorities<\/b><\/h3>\n
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OMIG Audits\u00a0<\/b><\/h3>\n
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NYS DOH Surveys<\/b><\/h3>\n
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Tips for audit and survey success<\/b><\/h3>\n
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