Elizabeth Hogue on Questionable Billing Practices to Fix Now

The Office of Inspector General of the U. S. Department of Health and Human Services issued Report OEI-04-11-00240 in August 2012, entitled “Inappropriate and Questionable Billing by Medicare Home Health Agencies.” Unlike some other guidance published the OIG, this report provides detailed information about inappropriate and questionable billing practices by home health agencies. Specifically, the OIG concluded that HHA billing is questionable or unusually high on the six measures below, if greater than the 75th percentile plus 1.5 times the interquartile range.

The six measures are as follows:

1. High average outlier payment amounts per beneficiary

According to the OIG, HHAs with outlier payments above $403 per beneficiary have unusually high outlier payments and are likely engaging in questionable billing practices.

2. High number of visits per beneficiary

HHAs that bill for 91 or more visits per beneficiary are engaging in questionable billing practices.

3. High number of late episodes per beneficiary

HHAs that bill for more than two late episodes per beneficiary are likely engaging in inappropriate billing practices.

4. High number of therapy visits per beneficiary

According to the OIG, 24 therapy visits per beneficiary is probably too many.

5. High payments per beneficiary

The OIG’s threshold for unusually high payments is $11,653 per beneficiary.

6. High average number of therapy visits per beneficiary

HHAs with at least 61 percent of beneficiaries for whom other HHAs billed Medicare are also likely engaging in questionable billing practices.

The OIG went on to say in the report that in 2010, 25 percent of HHAs exceeded the above thresholds for at least one of the above six measures.

There is good news and bad news! The good news is that HHAs now have specific information about what the OIG views as questionable, inappropriate billing practices. If you are one of these HHAs, you know you are in the “crosshairs.” Fix it right now! The bad news is that the OIG thinks that at least one-fourth of all home health agencies are engaging in billing practices that deserve further scrutiny. Enforcement actions hurt everyone, including patients. Fix it right now!

Contact Elizabeth E. Hogue, Esq. at (877) 871-4062 or via email by clicking here. Click here to follow Elizabeth Hogue on Twitter!

© 2012 Elizabeth E. Hogue, Esq. All rights reserved. No portion of this material may be reproduced in any form without the advance written permission of the author.

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