Corrected Reports to Be Issued February 25th
The Centers for Medicare & Medicaid Services awarded a contract to SafeGuard Services LLC to do Comparative Billing Reports. A CBR is a documented analysis that shows a provider’s billing patterns. According to the Medicare Program Integrity Manual section on CBRs, “The MACs have the discretion to give provider-specific comparative billing reports to providers with the highest utilization for the services they bill in order to address potential over-utilization.” CMS has expanded the use of and authority to issue CBRs outside of the MACs with this SafeGuard Services contract.
During a January conference call, the SafeGuard Services advised the National Association for Home Care & Hospice (NAHC) that CBR reports would be issued to home health agencies. Further they stressed that these reports are solely for the purpose of helping home health agencies by providing “access to meaningful information to compare their utilization with their peer group.” They stated that CBRs are not for the purpose of targeting inappropriate billing and are not shared with other CMS contractors unless requested. According to SafeGuard Services, the goal of CBRs is to “allow providers to look at the data and see if they need to improve.”
Recommendations about draft CBRs were solicited from NAHC. In response, NAHC advised SafeGuard Services that its number one concern is that the data presented inappropriately focuses on utilization as the determinant of questionable billing practices. In addition, the data is not risk adjusted. Further, the data presented fails to address the fact that many home health agencies serve specialized patient populations.
NAHC advised SafeGuard Services that issuance of the CBRs as they presented could have a chilling effect on home health services, leading to depriving Medicare beneficiaries of entitled care. NAHC urged that, if CBRs are to be of value, they should be risk adjusted for such variables as multiple co-morbidities, age, agency size, rural vs. urban area, and referral source. NAHC further recommended that CBRs focus on coverage, not just utilization, and that CBR contractors engage in education of providers whose practices conflict with coverage rules.
The first CBRs were sent to home health agencies during the month of January. These CBRs, which were produced by SafeGuard Services, were sent to home health agencies by A+ Government Solutions, the CBR disseminator. After receiving calls from providers about inaccuracies in their agency’s data, NAHC contacted SafeGuard Services. In response to NAHC’s report SafeGuard Services issued the following update:
“CBR022 was released early afternoon Thursday January 24th. Monday January 28th, our data analyst discovered a discrepancy in the data. An investigation by our statisticians was immediately launched. By Tuesday we were able to verify that a portion of the released report contained inaccurate data. In consultation with CMS, a corrective action was instituted. We began by notifying the Association of the discrepancy and our Customer Care Center initiated calls to every provider who had called in since the release to make them aware of the discrepancy in the report. A letter will be faxed or mailed out shortly to each provider that received a report informing them that a revised report will be released on February 25th. CBR Services regrets any inconvenience this may have caused and thanks the Home Health Provider community for their involvement and cooperation.”