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Other Health Care Providers

Home health agencies, durable medical equipment (“DME”) companies and other suppliers and providers of health care services also must be concerned with complying with the Anti-Kickback Statute and other Michigan and federal laws, rules, and regulations.  Each year the Office of Inspector General (“OIG”) publishes its work plan for the upcoming year.  The work plan sets forth the areas of law in which the OIG wishes to focus its efforts by overseeing and identifying unacceptable practices by health care providers and suppliers.  Some of the areas in which the OIG is focusing on whether various health care providers and suppliers are compliant with Michigan and federal law, are set forth below.

The Health Law CenterHome Health Agencies – OIG intends to take a greater oversight of Outcome and Assessment Information Set (OASIS) data submitted by Medicare-certified Home Health Agencies (“HHA”s), including the Centers for Medicare and Medicaid Services’ (“CMS”) processes for ensuring that HHAs submit accurate and complete OASIS data, compliant with the various laws. Federal regulations require that home health agencies conduct accurate comprehensive patient assessments that include OASIS data items and submit the data to CMS. OIG will review home health agencies OASIS data to identify payments for episodes for which OASIS data were not submitted or for which the billing code on the claim is inconsistent with OASIS data.  Because of the growing concern over questionable billing, the OIG will be examining home health agencies’ billings that exhibit certain characteristics that may indicate potential fraud under the law.

Nursing Homes and Skilled Nursing Facilities (“SNF”s)– With more Medicare beneficiaries being transferred from hospitals to post-acute care facilities, the OIG is focusing on the quality of care and safety of Medicare beneficiaries being transferred to SNFs, inpatient rehabilitation facilities (“IRF”s) and long term-care hospitals.  Particular attention will be on evaluating the transfer process and the identification of rates of adverse events and preventable hospital readmissions.  The OIG will be reviewing Medicare and Medicaid certified nursing homes and their implementation of compliance plans as it relates to the day-to-day operations, as identified in the OIG’s compliance program guidance. To identify abuse under the law, the OIG will identify questionable billing patterns associated with nursing homes, SNFs and Medicare providers for Part B services provided to nursing home residents whose stays are not paid for under Medicare’s Part A SNF benefits.

Hospices – Since it has come to Congress’ attention that hospices and nursing facilities may be involved in inappropriate enrollment and compensation under the law, OIG will be reviewing hospices’ marketing materials and practices and their financial relationships with nursing facilities.  The focus will be on reviewing hospices that have a high percentage of their beneficiaries in nursing facilities.

Medical Equipment Companies and Other Suppliers – While the OIG has made it a point to review Medicare contractors’ (durable medical equipment (“DME”), prosthetics, orthotics and other supply companies (“DMEPOS”)), enrollment and monitoring activities to identify applicants that pose fraud risks to Medicare law, the OIG has identified other areas of concern.  The OIG will review DMEs’ Medicare Administrative Contractor claims processing edits to prevent payment to multiple suppliers of home blood-glucose test strips and lancets.   Related to that, OIG will also review Medicare claims for diabetic testing supplies to identify questionable billing.

If you are a home health agency, DME provider, nursing home, hospice or other supplier of health care services and have questions as to whether you are at risk, contact The Health Law Center and speak to a qualified health law attorney at [email protected]

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