Audits from the U.S. Department of Health & Human Services’ Office of Inspector General (HHS-OIG) can often catch home health agencies by surprise.
And after a slower audit period during the COVID-19 pandemic, experts told Home Health Care News that providers should expect a ramp-up in audits over the next year.
Battling that element of surprise will be key to getting through a successful audit process.
“Having a very healthy, robust compliance program that really challenges the health of a home health agency internally is a good way to be ready for when an outside entity, like the government, does the same,” Bryan Nowicki, a partner at Husch Blackwell, told HHCN.
Home health agencies should be at a place where they aren’t just prepared for audits, but also expect them.
“Don’t be surprised if and when you get an audit,” Husch Blackwell Associate Erin Burns told HHCN. “It’s likely going to happen, and knowing that should help you be more prepared in the long run.”
What federal government audits are looking for
The audit process can be a long and arduous one.
“The audit process itself is — as we tell our clients — a marathon, not a sprint,” Burns said.
Knowing that audits are coming is part of the battle, Burns said. But knowing what OIG or other federal agencies are looking for is another piece to the puzzle.
Historically, audits done by OIG include the office taking 100 claims at random, evaluating those claims and then coming to an error rate. OIG will then extrapolate that error rate and assess it over the industry.
Other audits — like the ones done by unified program integrity contractors (UPICs) hired by the U.S. Centers for Medicare & Medicaid Services (CMS) — are used to investigate home health agencies for potential fraud.
“We have seen an uptick in UPIC activity across the board for home health this year and I think that relates, in part, to the government relaxing some of the COVID restrictions,” Nowicki said. “I think the audits will focus on the time periods when COVID was an issue and I think that’s something home health agencies will have to address.”
Many in the industry have expected OIG audits to proliferate in home health, like they have in hospice over the last few years. The home health industry could also see an uptick in audits from OIG on provider relief funds as well, Burns said.
Generally, both audit processes will look at financial data for home health agencies, homebound statuses, OASIS compliance and other factors that impact payment.
OIG is likely going to refine what exactly they are looking for on the other side of the pandemic, Nowicki said. However, what that looks like won’t be known for another year or so.
“We do know from the OIG audit we’ve been working on that the fundamentals are still there and they’re getting a little more precise in certain details that they’re looking into,” Nowicki said. “They’re also reserving their ability to change the focus of the audit if they find something that interests them.”
One of the first issues that comes to mind for Katie Wehri, the director of regulatory affairs for the National Association for Home Care & Hospice (NAHC), is the lack of understanding by the general public and home health consumers about the OIG audit process.
Wehri also said it’s important for home health providers to know that the routine “Work Plan” audits from OIG are not targeted audits.
“Home health agencies need to remember if they receive a request for a record from one of the audits being conducted from the OIG’s Work Plan, that the audit is not targeting the provider,” Wehri said in an email. “The audit is targeting all home health services and the OIG usually includes 100 claims as part of the review.”
If everything on the books is in good shape, home health agencies shouldn’t fret much about those.
“Documentation is key in compliance programs,” Burns said. “Hopefully they are keeping up with their compliance program, documenting their efforts, doing internal reviews on policies and procedures and making sure those mirror and support their internal processes.”
Being compliant is one step. Having a prepared team in place is the next.
“Being ready to deal with requests when they come in and knowing who is going to be on the team that’s going to address that,” Nowicki said. “How does that group get together? And if you have that infrastructure – the audit response infrastructure in place before you even get that letter – then you’re going to be better served in responding to what are often pretty short turnaround times.”
Wehri agreed, and said that ensuring staff members are on the same page and abreast with the latest information is key to getting through the process scot-free.
“Home health providers need to ensure that the agency staff recognizes and knows the internal processes for handling an audit request from the OIG,” she said.