HEALTHCARE COMPLIANCE 2 – Discussion (HOME CARE) Among the biggest changes to home care in 2018: the fact that federal policymakers will allow some non-ski
Among the biggest changes to home care in 2018: the fact that federal policymakers will allow some non-skilled in-home care services under the Medicare Advantage (MA) program starting next year.
What are you thoughts of these new changes?
this is the link to help with the question: https://homehealthcarenews.com/2019/01/the-top-trends-in-home-care-for-2019%EF%BB%BF/
Hospices and Home Health Agencies
Contrasts between hospices & home health agencies
Common fraud types in these entities
Benefits of an effective compliance program
Implementing a 7-element compliance program
Purpose of a Code of Conduct
Risk areas unique to hospices & home health agencies
Fraud between hospices and nursing homes
“Home care organizations” include home health care agencies, home care aide organizations, and hospices.
The two types of these entities that have received the most attention from the OIG are hospices and home health agencies.
The Hospice Care Industry
The Home Health Industry
The Hospice Care Industry (I)
Hospices provide expert medical care, pain management, and emotional and spiritual support tailored to the needs of terminally ill patients.
A hospice focuses on caring, not curing.
In 2011, approximately 1.65 million patients received services from a hospice.
The Hospice Care Industry (II)
Of these, one million patients died under hospice care, 300,000 were discharged alive, and another 300,000 remained under hospice care.
The Hospice Care Industry (III)
In 2010, Medicare expenditures on hospice care totaled about $13 billion.
They were the major (84%) source of payment for hospice care.
Four general levels of hospice care:
Level 1. Routine Home Care
Level 2. Continuous Home Care
Level 3. General Inpatient Care
Level 4. Inpatient Respite Care
The Home Health Care Industry
Home health care allows homebound individuals to stay in their homes by providing medical equipment and services to them in their homes.
Medicare pays for skilled nursing services, home health aide services, physical and occupational therapy, speech-language pathology, medical social services, medical supplies other than drugs and biologicals, and durable medical equipment.
In 2011, about 3.4 million Medicare beneficiaries received home health services from 11,633 HHAs.
OIG Guidance for Compliance Programs
OIG standard structure for a compliance program
Standards, Policies, and Procedures
Compliance Officer and Committee
Training and Education
Reporting and Investigating
Enforcement and Discipline
Monitoring and Auditing
Response and Prevention
Benefits of an Effective
Demonstrate commitment to responsible provider and corporate conduct
Identify and prevent illegal & unethical conduct
Improve quality & consistency of patient care
Enable employees to report potential problems
Facilitate investigation of alleged misconduct
Initiate immediate & appropriate corrective action
Minimize exposure to civil & criminal legal penalties
Standards, Policies, and Procedures
Code of Conduct – broad guidelines for employees, managers, contractors, vendors, and clinicians in the performance of their jobs
Policies & procedures – prescribe in detail how specific tasks in high compliance-risk areas are to be carried out
Compliance Risk Areas Unique to Home Health Agencies
31 areas in HHA program guidance
Claim Development and Submission
Medical necessity, homebound beneficiaries, physician certification of plan of care, cost reports
Anti-Kickback and Physician Self-Referral laws
Compliance Risk Areas Unique to Hospices
28 areas in hospice program guidance
Terminal illness as an eligibility requirement, plan of care, levels of hospice care
Hospice Arrangements With Nursing Homes
Other Elements of a Compliance Program for HHA’s and Hospices
Compliance – a factor in performance appraisals
Establishment of a compliance infrastructure: Compliance Officer and Compliance Committee
Compliance training and education
Lines of communication for complaints/reports
Disciplinary action for non-compliance
Auditing and monitoring compliance efforts
Responding to and correcting non-compliance