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Posts tagged ‘Haydel Consulting Services’

Bad Blood


I know Elizabeth Holmes. Chances are you do, too.

I have never met her or spoken with her but I recognize her. I see some former clients in the pages of John Carreyrou’s, Bad Blood: Secrets and Lies in a Silicon Valley Startup. Holmes has the distinction of being the youngest female billionaire but fraud evens out the playing field. Right now she is worth about nothing and Theranos, her company, is but a memory.

Theranos was going to revolutionize the lab industry with a device that would run over a hundred lab tests with blood from a single fingerstick.

My first thought was who needs that much information?

It doesn’t matter who needed it because it never worked. In order to use the blood, the sample had to be diluted and that never turns out well when there are tiny variations in concentrations of very little blood causing major deviations in results.

Reading Carreyrou’s book was like reading a clinical record of a psych patient without authorization. Elizabeth Holmes had but a passing acquaintance with the truth and it’s anybody’s guess where her fantasies stopped and her lies began.

It helped that she was very well connected. Her board of directors could take down small countries before lunch just for fun. Henry Kissinger, George Schultz, Sam Nunn and more believed in her. George Schultz’s grandson, Tyler worked for Theranos for a period of time that ended with estrangement from his family and almost a half a million dollars in legal fees.

As far as employees went, she hired the best but nobody lasted. Problems brought to her attention about the product not working were met with the proverbial axe. Others had a life outside of work and that was clearly contrary to the company’s unwritten policy. They quit.

Can you imagine hiding your operations from CMS auditors?

When an employee on leave committed suicide, Theranos barely recognized the employee’s absence. When her idol, Steve Jobs, died, an Apple flag was flown at half mast outside of Theranos.

Anyone who has ever worked for a fraudulent agency will recognize Theranos. I am sure that every one of her former employees is embarrassed for having believed in her ‘vision’. All of them can see the lies in hindsight and are kicking themselves for not asking the hard questions earlier. There should be an address to send sympathy cards to former Theranos employees.

If you haven’t ever had close contact with a truly fraudulent employer, read Carreyrou’s book and maybe you never will. But don’t count on it.

Work Place Violence (and free CE’s)


workplaceviolence_bannerI must say that everyone is pretty good about conducting a home safety assessment. Throw rugs are removed, lights are bright and shiny and and much of the work done by therapists is to reach the goal of the patient being able to safely navigate in the home environment. Geaux, Team!

We’re missing something. What about employee safety in the work environment? Everyday home health and hospice nurses, aides, MSW’s and social workers go into homes where they are separated from the agency and out of view of anyone who might help them. All but the most serious incidents are overlooked.

In addition to the injuries that happen regularly such as sprains, abrasions and other musculoskeletal injuries due to moving patients, these are routinely addressed in orientation and annual inservices. A risk of workplace violence also exists and recent research shows it is more prevalent than you may think.

Homecare workers (n = 1,214) reported past-year incidents of verbal aggression (50.3% of respondents), workplace aggression (26.9%), workplace violence (23.6%), sexual harassment (25.7%), and sexual aggression (12.8%). Exposure was associated with greater stress (p < .001), depression (p < .001), sleep problems (p < .001), and burnout (p < .001). Confidence in addressing workplace aggression buffered homecare workers against negative work and health outcomes.1

The CDC along with NIOSH has published an online Continuing Education course addressing workplace violence for healthcare workers. It is not specific to visiting nurses but does offer useful advice. It also offers 2.4 continuing education credit but if you want the credit, read the ‘instructions for credit on the first page. It is provided at no cost and includes short video clips, written text and discussion questions.

In taking this course, I learned that when adhering to the strict definitions of Workplace Violence, many homecare workers have experience with verbal and physical aggression. We also under report workplace violence and ‘forgive’ our patients. It may be a fact of life that nurses eat their young but it doesn’t have to be and agencies should not tolerate bullying of their employees. Regardless of the kind of workplace violence that takes place, visiting staff may suffer stress, depression, insomnia and burnout as noted in the study cited above. Without support from management, the agency’s morale will deteriorate to the point where nothing gets done.

If you know of any other resources to reduce the risk of workplace violence in the workplace, please share in the comments. Our workplace includes most zip codes in the country and all types of people. Reducing the risk of violence and supporting visiting workers can go a long way to making sure you’re agency doesn’t lose its best employees to burnout.

  1.  Hanson, G. C., Perrin, N. A., Moss, H., Laharnar, N., & Glass, N. (2015). Workplace violence against homecare workers and its relationship with workers health outcomes: a cross-sectional study. BMC Public Health, 15, 11. http://doi.org/10.1186/s12889-014-1340-7

Novus Hospice

Novus Hospice in Frisco accused of aggressively managed length of stay numbers by overdosing patients on continuous care.

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A 36 Billion Cottage Industry

How home health and hospice visiting nurses can recognize financial exploitation of the elderly and who to call when they do.

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UPIC


I admit that I was a little hopeful, if not disillusioned, when the new UPICs came to my attention.  After verifying that UPIC was not a ZPIC with a typo, I thought that maybe this was a special type of audit where you got to pick the charts you wanted to be reviewed like some people pick their own lottery numbers.  No such luck, I’m afraid.

UPICs are Unified Program Integrity Contractors.  UPICs will carry out program integrity functions for Medicare Parts A, B, Durable Medical Equipment Prosthetics, Orthotics, and Supplies, Home Health and Hospice, Medicaid and Medicare-Medicaid data matching[i].  The primary objective of the UPIC is to identify fraud and abuse and make appropriate referrals.  Other agencies recoup overpayment and address recommendations to law enforcement addressing criminal or civil charges.  They can also recommend suspension of payment.  Whether or not the agency is notified in advance of the payment suspension depends on if the UPIC thinks it is possible that the provider will change it’s billing habits if it knows that payment will stop.  Think about that for a minute.  Who wouldn’t change their billing habits if they knew payment was coming to an abrupt halt?

UPICs, like ZPICs can request clinical records, verification of licensure, copies of claims, etc.  The most recent UPIC request I read included a host of new horrors that may not be available and/or are too cumbersome to send.   Here’s a short recap of some of the new things but remember, they can always ask for more or even go to your office to visit.

  1. Copy of the face sheet. I have never used this term in home health or hospice, but it is basically patient demographics and insurance information.  People who have experience in a hospital are likely familiar with this term.
  2. Copy of Medicare card and state identification card (driver’s license or state ID). The logistics of getting a copy of the Medicare card and state identification card involve too many opportunities for loss and theft that I don’t recommend it even if Medicare wants it.  However, Medicare and other payor sources lose money daily when somebody loans (rents) their Medicare/Medicaid card to someone else.  Some software systems allow you to post a picture of the patient on the face sheet.  DNA and fingerprints are not necessary, but the end of the earth is not too far to go if there are any doubts. 
  3. Authorization of benefits. This is almost universally included in the consent form given to patients.  Take a quick look and ensure that somewhere on the consent it says that the patient or representative authorizes the agency to bill Medicare for services.  It would hurt a lot if this statement was inadvertently omitted when all those changes were made to the form relative to the new Conditions of Participation.
  4. EHR Audit Trails. In most systems, these audit trails are cumbersome to obtain and require someone to print or save the audit trail for each individual document.  In one system, the audit trail can be over 100 pages for a single document.  For a long time, there was a vendor who provided audit trails on request, but the agencies were not able to run them.  If you get a UPIC, consider the burden to your agency and call the person who signed your UPIC letter.  It kind of makes paper charts seem appealing again.
  5. OASIS to include the start of care, the resumption of care certification prior to and after the dates of services noted in this request and the discharge. I’m not entirely sure what this means.  To the best of my knowledge, patients aren’t certified after Resumption of Care unless the patient was in the hospital at the end of the episode and there is no change between the recertification assessment (not mentioned) and the ROC HIPPS code.  If an agency has a reasonable hospitalization rate, this is a rare occurrence.  Plus, there are numerous other bullets in the list that mention OASIS assessments.
  6. Travel Logs. Some agencies don’t have travel logs.  Some don’t pay mileage and others pay a flat ‘trip fee’.  I would think a visit log would be more useful to the UPIC but in the two page request, that wasn’t mentioned.

There are many more entries in the UPIC request but even though the length of the list is daunting, it is repetitive.  Laboratory results are requested on page one and all diagnostic tests are requested on page two.  There are individual entries for all hospital documentation, Inpatient records, Inpatient records to support start of care, inpatient records for hospitalizations during the episode, emergency room visit notes and the history and physical.  The best advice I can give is to be careful when delegating the tasks on the list, so you don’t have multiple employees all printing OASIS assessments.

The good new is that most of you will not find yourself in the undesirable position of being the target of a UPIC. If you are one of the unlucky ones, well, it’s not luck that brought you the unwanted attention from a UPIC.  The data analytics are very sophisticated and there is nothing random about the selection of charts (which makes me wonder why a copy of your Medicare Census is included in the list of documents required from the agency.  They know who your patients are.)

That doesn’t mean that your agency is operating outside of coverage guidelines.  It does mean that cloned notes, poor coding, lack of OASIS skills and care plans that are copied from one episode to the next will be under the spotlight.  This results in paying money back to Medicare and additional scrutiny which may extend to your referring physicians who might then begin referring patients to your competitors because they don’t like attention from Medicare any more than the rest of you do.  I do not like it when care is provided to eligible beneficiaries gets denied because a nurse is a little too eager to show off his or her new cut and paste skills.  It’s not like the agency can recoup their paychecks.

Questions?  Comments?  Do you have any experience with UPICs?  Post your comments below or email us.  We need to know now so we can understand them before they become obsolete.

[i] From Noridian Healthcare Solutions

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