Everyone agrees that the industry has had enough of fraud. In fact, some industry leaders have already declared, ‘Enough is enough!’. I wholeheartedly concur with that eloquent and emotional pronouncement of the common values of Home Health Providers. So lets take a look at how we can reduce fraud and cut the home health budget, shall we?
- Ensure that nobody gains entry into the Medicare program without undergoing a criminal history background check.
- Test all owners and managers according to standards set forth by The Secretary to ensure that all owners and managers understand HIPAA, coverage guidelines, compliance rules, marketing guidelines, etc.
- Require providers to put up a 100K surety bond and demonstrate they have the capital to operate.
- Mandate compliance programs or if you prefer, ‘Promulgate rules requiring home health agencies to have in operation a compliance and ethics program designed to prevent and detect criminal, civil, and administrative violations’.
- Do not issue provider numbers in geographical areas where there is a lot of fraud or where there are a lot of providers.
- Put a Cap on Episodes much like IPS. Urban agencies will be limited to less than two episodes in the aggregate and rural agencies can go up to 3.2.
- Penalize agencies who do not bill for LUPA’s.
- Have the MACs (FI’s) perform a payment review on a random sampling of claims in all agencies to make assumptions about the agency based upon OASIS data prior to paying claims to ensure accuracy of claims. I am available at my hourly rate to assist agencies in this process which resembles RAC audits.
- Place all new agencies or agencies that acquire new provider numbers to them on a 100% percent prepayment review of claims.
- Get rid of the therapy thresholds.
- Tighten up the face to face encounter time frame so that all patients except those who have just been discharged from the hospital must be seen within 14 days of admission..
- Allow Nurse Practitioners to sign plans of care.
It is possible that one or two of you are sitting there wondering how I ever became so brilliant and are willing to stand up and fully support these recommendations.
It is equally possible that some of you think I am knitting with one needle or that my IQ roughly equals room temperature this weekend.
As such you would all be wrong. These suggestions have already been presented to Congress by The Limited Partnership for Quality Home Health Care. Click on the link to view the eight (8) members of The Partnership. Is anyone surprised by anyone on the list?
In case you think that Bill Borne and his friends are just trying to mess with me, I encourage you to read their petition to congress. It describes an entire proposed Act of Congress called the SHHIPS Act.
I have never had an act of congress – even proposed – named in my honor. I want a Planet Wackadoo Act that eliminates stupid and/or greedy people from health care. Better yet, what about a Put Patients First Act that prohibits determining care based upon arbitrary numbers that coincidentally benefit the Elite Eight at the expense of the group of the other approximately 6,000 home health companies in the country?
As the week goes by, I will share my thoughts on the individual recommendations. Meanwhile, we have a voice. If you have any strong opinion about the SHHIP – even if you disagree with me, use your constitutionally guaranteed right to be heard by those you elect to office.
Now, go for a long walk, get some tea and clear your head. We have work to do.