In order to bill Medicare for home health services, all notes, orders and clinical documentation for the episode must be signed and in the medical record prior to dropping claims. Sounds simple, right? Homecare 101. And yet, our whole industry is plagued by rumors. Like old wives’ tales some of these false beliefs become so embedded within an organization that nobody has a clue that they might be doing anything inappropriate. Here are two of the billing myths I have heard lately:
- Since agencies are paid per episode, it doesn’t matter if all visit notes are in the chart prior to billing. Only therapy notes are required to be in the chart prior to billing. And yet, here is what the OIG suggests as part of a plan to ensure that agencies comply with Medicare billing guidelines:
Provide for sufficient and timely documentation of all nursing and other home health services, including subcontracted services, prior to billing to ensure that only accurate and properly documented services are billed; Emphasize that a claim should be submitted only when appropriate documentation supports the claim and only when such documentation is maintained, appropriately organized in a legible form, and available for audit and review.
- If an order is written after an episode ends such as when auditing clinical records, it is not necessary to wait for signatures because the order was not written during the duration of the episode. Here is how Palmetto GBA tells us to avoid denials:
When responding to an ADR, verify orders for all services billed are included with the medical records. Ensure physician orders, for all services billed, are obtained prior to providing the service and prior to billing Medicare, and are submitted for review. Ensure all oral/verbal orders are countersigned and dated by the physician before the final claim is billed to Medicare. In the event the physician fails to date his/her signature, write or date stamp the date the order was received back from the physician. The stamp date must include the word “received” and should be in black ink, as red and blue ink will not photocopy.
Even though it is not mandatory that agencies have a compliance plan, there are many good reasons to implement one. Chief among them is a promise by the Office of the Inspector General that sentencing guidelines are influenced by the presence of a compliance plan. Regardless of whether your agency chooses to implement a formal plan or not, these billing guidelines are mandates and must be followed. To do otherwise is to put your agency in serious regulatory or financial risk.
We always welcome your comments and questions below or if you choose, you may email us at email@example.com. As always we are available to assist agencies in implementing a corporate compliance plan. If you choose to go it alone, please refer to the OIG sample compliance plan.
The OASIS-C revised version 12.4 can now be accessed by clicking on the link to your left under the Blogroll. The 12.2 dataset has been removed from our site to avoid confusion. Changes are minimal and we look forward to telling you more about this important change in our industry.
Also, it is time to think about compliance with the Red Flags Rule. Please click the link for more information on how to become compliant.
As always, if you have any questions, please comment below or send email to firstname.lastname@example.org.
Agencies often ask what they can do in order to pass survey. Frankly, there’s so much to do in order to pass survey that it is easier to ask how to bomb survey. And I have firsthand knowledge on how to completely bomb a survey. Follow the instructions below and it is almost guaranteed that you will find yourself in survey hell shortly after the state comes knocking on your door.
- Hire anyone who is available. Do not waste your time checking references or verifying licensure. Supervise staff only when convenient. Play ignorant when you learn that the DON doesn’t have the required experience to be in position.
- Honesty may be the best policy but not if you want to bomb survey. Give a surveyor just a hint that you might be fudging on the facts and your survey will go south in a heartbeat.
- Show your creative side by manufacturing notes and documents as they are requested from the surveyor.
- Explain to the surveyors that your referring physicians are too busy to address patient problems so you haven’t actually contacted any of them when blood sugars fall or blood pressures rise.
- Write your therapy frequencies after the visits are made to ensure they are accurate.
- Admit numerous patients from physicians who are not licensed to practice. This strategy works best if you can produce documentation that you tried to verify their license but couldn’t find their name in the Medical Board’s database.
- If you are the Director or an owner of an agency, distance yourself from the staff by calling them stupid. It will make you look brilliant and undoubtedly cause questions about agency leadership ensuring poor survey results.
- Explain that your hospitalization rate is higher than state average because your on call nurse drinks most weekends and you have no choice but to send your patients to the hospital.
- Refuse to let the surveyors in the door. I’ve only seen this once (not our client by the way) but thus far, this technique has a 100 percent success rate when it comes to having a license revoked.
- And obviously the easiest and surest way to bomb survey is to forge signatures.
If you refuse to follow these guidelines, it is entirely possible that you will pass survey regardless of how many honest mistakes you have made. When it comes time for survey, agencies that tend to their patients’ needs, pay close attention to documentation and are open and honest with surveyors usually pass. Deficiency free surveys are bragging rights but an honest survey with one or two tags that don’t relate to patient care is a huge success.
So my best advice to anyone seeking to pass survey is just breath. It will be fine. You really have to put some effort into bombing a survey if you take good care of your patients and your documentation matches what you do.
Please note that Haydel Consulting Services LLC does not enter into business relationships with agencies who wish to fail survey. For other purposes we can be reached at Haydelconsulting@bellsouth.net or at 225-216-1241.
Anyone who has been in home care for any length of time knows better than to change all their processes for changes slated to occur in nine months. And yet, if you have been in home care that long, you know that waiting to the last minute is also not a viable option. The question I am facing with my clients currently is how to prepare for OASIS-C now so that when it is time for complete implementation it won’t be as painful. The answers I want to give are those that benefit the agency now and will ease the pain of OASIS-C implementation.
Below are five things that you can do now in order to prepare for OASIS-C. More than ever we want your comments so that we can add to the list for everyone’s benefit in the coming weeks and months.
- Implement a ‘real’ fall prevention program. Monitor results. Fall Precautions are about more than removing throw rugs! Get physical therapy and occupational therapy involved.
- Assign a staff member to begin preparing for next year’s flu season so that a plan exists to monitor the vaccination status of all patients. Prepare consent forms and order templates to ensure that your staff are ready to attack the flu head on in October.
- Call your wound care supply vendors. Ask for education. An abundance of programs are out there, free of charge to agencies. Wound care needs to be taken to the next level in home health.
- Run a list of all patients with heart failure as a diagnosis. See if your agency is weighing patients, monitoring electrolytes, and preventing hospitalizations. Design a program to meet your agency’s needs.
- Begin use of the PHQ-2© Pfizer Depression screen or determine the screen you will be using and implement now.
This list is just a beginning. But hopefully everything on this list will benefit patients beginning now. It is simple and can be fully completed within a month. Hopefully by then, we can publish another to do list.
Please comment below or send emails to Haydelconsulting@bellsouth.net.
We have finally submitted our comments regarding the proposed OASIS-C dataset. You can view them here.
- In short there will be 40 new questions on OASIS C that are not currently on OASIS B-1
- 10 questions that we currently answer on B1 that will not be carried over to OASIS C
- 70 questions that were on OASIS B1 that had their MO numbers changed. Note: Most MO numbers have been replaced with M numbers
- 50 of the 71 questions that had a numbering change also had a change in the language or skip pattern
- 21 changes were merely numbers.
You comments as always are always appreciated. Please email us at Haydelconsulting@bellsouth.net or leave a comment below.