When a public health emergency was declared last March, the Medicare & Medicaid Service Center (CMS) made it easier for home healthcare providers to provide telemedicine services amid the ongoing COVID-19 crisis. We have issued various exemptions to allow you.
The Inspector General (OIG) has now announced an audit called the “HHA Telehealth Project”. This audit will investigate telemedicine usage by home healthcare providers last year, while flexibility is recognized.
Audits are intended to evaluate home health services provided by deciphering whether an institution manages and claims services in an appropriate manner.
“There is a problem with telehealth and OIG believes it could be a fraud,” Matthew Schatskez, a partner at law firm Shepherd Marine, told Home Healthcare News. “As a result of the pandemic, there was this crazy scramble to allow us to move from face-to-face services to another modality in telemedicine. As a result, these increased flexibility are in the area of non-compliance. I think it could be connected. “
OIG’s mission is to provide objective oversight of the US Department of Health and Human Services (HHS) program. The Watchdog Group uses risk analysis and vulnerability assessment tools to create work plans.
The original plan for telemedicine audits for home health care was announced in January but was revised last week. The final report will be published in 2022.
The purpose of these OIG reports is to prevent, detect, and stop the potential for fraud, waste, and abuse. The office reports improperly billed services and makes recommendations to the CMS based on the results of the project.
“In the past, other audits conducted by government agencies have seen them send the first request for sampling records and then go from there,” Shatzkes said. “It’s interesting to see what kind of provider receives an audit request (the sample size requested) and how OIG will ultimately handle it.”
Within the waiver clause of Section 1135 issued, physiotherapists, occupational therapists, linguistic pathologists, and other non-physician practitioners were capable of opening telemedicine cases.
CMS also uses telemedicine along with face-to-face services by home care providers as long as the use of technology is related to the services offered and includes instructions on how to supplement care plans. I adjusted it so that it can be done.
It is still unclear how accurately OIG will select the providers to audit. However, the bandwidth of OIG may not be large enough to investigate a large number of institutions. That is, you may choose a smaller sample size.
Critics have pointed out that home health care has been fraudulent in the past, despite autonomous efforts to eliminate malicious individuals over the last decade. But that’s not the only concern for telemedicine in this sector for OIG.
Telemedicine has been used in unprecedented amounts and in unprecedented ways in public health emergencies.
Prior to COVID-19, only 11% of patients in the United States used telemedicine. But in 2020, 46% of patients used telemedicine instead of traditional medical visitsAccording to a survey by McKinsey & Company.
If this is the way to the future, it makes sense for OIG to want to explore how it is used — and whether it is properly used in the Medicare dollars.
“At some level, I think it’s just an exploratory mission to get a feel for it,” Schatskez said. “At the same time, I think there is a general concern about increased flexibility and those who try to take advantage of it. Sometimes it’s not a malicious purpose of any kind, but one bad apple spoils the bunch. . “
Auditing does not necessarily represent all the bad news for providers.
There is debate at both the state and federal levels as to whether these flexibility should be maintained after a public health emergency. The OIG project may indicate that more serious consideration is being given to increasing telemedicine reimbursement support for home care in the future.
“I think at some level, what audits might look like. [everything] It was used, “said Schatskez. “Because they have to make a decision as to whether their flexibility should be maintained beyond the emergency period of public health.”
It’s not just about family health. These types of audits can continue throughout healthcare as the pandemic subsides and flexibility expires elsewhere.
How providers should respond
Yes, government agencies need to avoid fraud to avoid being targeted by OIG.
But it’s not that simple. Providers have the right to worry if all ducks are in line. The first step is to make sure the document is organized and running.
“I think the documentation is really important,” said Shatzkes. “It’s about making previously rendered records and services as button-on as possible.”
For institutions that haven’t gone so far, if OIG comes after them, it can be a potential problem.
“If it’s not understood, there’s clearly a limit to what we can improve,” Shatzkes added. “But in the future, providers will certainly need to make sure they have the proper documentation for the services offered.”
It’s unlikely to be targeted, but documenting and billing is always helpful to speed things up anyway.
In addition, if the family medicine sector is well documented in audits, or at least okay, it may indicate to the federal government that the industry deserves more flexibility related to telemedicine in the future.
In addition, it is important to pay attention to telemedicine audits Not the only active project in OIG It is related to home medical care.
For example, in January, Watchdog published a review titled “Home Healthcare Challenges and Strategies in Response to the COVID-19 Pandemic.” In September, we began reviewing infection control at home medical institutions during a crisis.
OIG has also been analyzing new local add-on payment methods since July.
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