Home Health & Hospice

VA Acupuncture Audits of Non-VA, Community Providers are Increasing

(May 20, 2022): Acupuncture audits and investigations by federal, state and private payors have greatly expanded in recent years. One of the most active players conducting acupuncture audits today is the U.S. Department of Veterans Affairs. (VA). It is worth noting that long before traditional Medicare even considered covering acupuncture services,[1] the VA made these …

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State and Federal Hospice Audit and Investigation Efforts are Expanding in 2022

(May 12, 2022): Hospice agencies are again the focus of both state and federal investigators and prosecutors around the country. The number of hospice audits and investigations at both the state and federal levels have risen in 2022. This isn’t surprising given the ever-expanding level of beneficiary participation and cost of Medicare’s hospice benefit program. …

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A Look Back at Hospice Audits and Prosecutions in 2020 — Are You Ready for 2021?

(December 28, 2020):  Let’s face it, we are all glad to have 2020 behind us.  From an enforcement standpoint, COVID-19 greatly impeded the Federal government’s ability to investigate and prosecute civil and criminal violations of law.  The numbers speak for themselves.  Between February 2020 and April 2020, new criminal prosecutions had dropped by 80%.[1] Although …

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Home Health Revocation Actions by Medicare are Expanding Around the Country

(September 28, 2020):Last September, CMS published a Final Rule titled “Medicare, Medicaid, and Children’s Health Insurance Programs; Program Integrity Enhancements to the Provider Enrollment Process.” [1] Among its many changes, the Final Rule significantly expanded the reasons that may be asserted by the Centers for Medicare and Medicaid Services (CMS) when revoking a health care …

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Recent Developments in Personal Care & Community-Based Services in Medicaid and Medicare

(March 23, 2020): Until recently, personal care services, such as home health aides, were not covered under the Medicare program unless they were part of a skilled service where the beneficiary was homebound.  However, beginning with calendar year 2019, the Medicare program has expanded the ability of plans that participate in the Medicare Advantage program …

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OIG Has Identified Common Errors by High-Risk Home Health Agencies.  Does Your Home Health Agency Have These Documentation Problems?

(September 30, 2019):  On September 5, 2019, the Department of Health & Human Services (HHS), Office of Inspector General (OIG) published an HHS-OIG Data Brief entitled “The Centers for Medicare & Medicaid Services Could Use Comprehensive Error Rate Testing Data To Identify High-Risk Home Health Agencies.”[1]  The purpose of OIG’s review was two-fold:  First, OIG …

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Home Health Agency Alert: The Review Choice Demonstration Project start dates for Ohio, Texas, North Carolina and Florida are Around the Corner!

(August 7, 2019): This article further updates our articles of February 19th and April 9th on the announcement by CMS of the implementation of the new five year “Review Choice Demonstration Project’ in five states – Illinois, Ohio, Texas, North Carolina and Florida, and the start date for the Demonstration Project in Illinois.   I. …

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Home Health Agency Alert: The Review Choice Demonstration Project is Moving Forward in Illinois Effective June 1, 2019

(April 9, 2019): This article updates our article of February 19 on the lifting by the Centers for Medicare and Medicaid Services (“CMS”) of the moratorium on the enrollment of new home health agencies in Florida, Illinois, Michigan and Texas, and the announcement by CMS of the implementation of a new five year “Review Choice …

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CMS has Ended its Moratorium on New Home Health Agencies in Texas, Illinois, Michigan and Florida. Unfortunately, the Lifting of the Moratorium Isn’t Necessarily a Good Thing for Existing Home Health Agencies.

(February 19, 2019):  CMS has now ended, at least for the current time, the moratorium that it placed on the approval of new home health agencies.  At the same time, home health providers that operate in Illinois, Ohio, North Carolina, Florida and Texas, and potentially other states within the Palmetto/JM jurisdiction (Alabama, Arkansas, Georgia, Indiana, …

CMS has Ended its Moratorium on New Home Health Agencies in Texas, Illinois, Michigan and Florida. Unfortunately, the Lifting of the Moratorium Isn’t Necessarily a Good Thing for Existing Home Health Agencies. Read More »

Texas Prosecutors are Aggressively Targeting Criminal Home Health Fraud

(January 9, 2019):  Despite real progress being made with respect to regulatory compliance, home health agencies, their owners, and affiliated health care professionals (such as referring / supervising physicians, therapists and staff) remain under strict government scrutiny. The government’s efforts to investigate and prosecute home health fraud cases have been especially evident in Texas.  In …

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