Under the OIG Microscope – Home Health and Hospice. Deborah Randall, JD Health Services & Telehealth Advisor [email protected] 202-257-7073. Why the Increased Scrutiny. History – Operation Restore Trust in the 1990’s affecting Home Health Medicare
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Deborah Randall, JD
Health Services &Telehealth Advisor
DIABETES INJECTION VISITS
DIABETES SELF-MANAGEMENT PROGRAMS - GEOGRAPHICS
1. Does hospice have correct distinction for administrative physician services including service on the IDT, as medical director or consulting physician advising the hospice entity which are non-billable
=> Teachable moment; audit topic
=> Compliance documentation and control moment. Fraud and kickback potential for physicians who will receive 100% pass through from hospice, but 80% Part B if physician billed
Compliance concern = > are referring physicians who are also contracted to the hospice getting paid for more visits than the average patient whose physician does not have a relationship with the patient? RAC, ZPIC and MAC also are concerned about this.
Compliance hotspots => Is service related to the terminal illness; is the Part B billing for certification and recertification of a care plan, or is that absorbed into the work of the IDT; is the medical director referring to the hospice and is she/he in an administrative home visit.
1.long duration cases;
2.non-cancer diagnoses especially Alzheimer’s,debility, Parkinson’s and ALS;
3. patients residing in nursing facilities and
4. the documentation which supports or not the reasonable determination of terminality.