OIG Find CMS in Compliance with HHA Survey Requirements

The Office of Inspector General completed a study to examine the performance of Centers for Medicare & Medicaid Services contractors conduct of home health agency surveys at least every 36 months and deficiency citation history. This study was carried out as a follow-up to a 2008 OIG study that found that many HHAs had the same deficiencies cited during multiple recertification surveys and CMS rarely used the only sanction available — termination — to address HHA noncompliance.

The goals of the new study were:

  • To determine the extent to which State survey agencies (State agencies) and accreditation organizations conducted recertification surveys of home health agencies within required timeframes.
  • To determine the extent to which HHAs received deficiency citations on recertification surveys and the nature and resulting actions of those deficiencies.
  • To determine the extent to which HHAs had complaints lodged  – i.e. allegations made – against them, the nature of those complaints, and the actions resulting from those complaints.
  • To determine the extent to which the Centers for Medicare & Medicaid Services used “look-behind” surveys to assess the performance of surveyors.

The OIG used data from fiscal years 2010 and 2011 as their source of information to identify the extent to which State agencies and accreditation organizations conducted timely recertification surveys. In addition, OIG analyzed deficiency citations, corrected deficiencies, and complaints. Finally, OIG analyzed whether CMS used look-behind surveys to assess the performance of accreditation organizations and State agencies.

At the conclusion of the study OIG determined that home health agencies received timely surveys and corrected deficiencies as required. However, OIG concluded that, although CMS conduct of look-behind surveys for accreditation organizations was adequate, CMS rarely conducted look-behind surveys for oversight of State agencies. Details of OIG findings include:

  • Surveyors conducted recertification surveys on time for 98 percent of HHAs
  • Surveyors cited 12 percent of HHAs with condition-level deficiencies
  • Among the HHAs with condition-level deficiencies, 93 percent corrected all deficiencies within required timeframes
  • Surveyors conducted complaint surveys for virtually all of the 15 percent of HHAs that had complaints lodged against them
  • State agencies conducted look-behind surveys of 14 percent of HHAs surveyed by accreditation organizations, exceeding CMS’s 5-percent standard
  • CMS rarely conducted look-behind surveys for oversight of State agencies’ surveys of HHAs.

CMS concurred with the sole OIG recommendation that CMS analyze data and determine the need for more look-behind surveys of State agencies. CMS central office will work with the CMS regional offices to identify State agencies with the greatest need for look-behind surveys.

Appendix A-1 and A-2 lists the number of condition level deficiency citations by State and the number of condition level deficiencies cited by accrediting organizations.

Appendix B details the number of complaints filed and substantiated by type of complaint.

The full OIG Report is available here.

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