OIG 2011 Work Plan: Home Health Agencies

The OIG will examine a number of Home Health Agency (HHA) issues, a number of which are provided in this entry. The OIG will scrutinize payments made under Part B’s HHA prospective payments. The Social Security Act requires that all services provided under a plan of care of an HHA be paid to the HHA, including payment for services and supplies provided under arrangements by outside suppliers. The OIG will “identify Part B payments to outside suppliers for services and medical supplies that are included in the HHA prospective payment and examine the adequacy of controls established to prevent inappropriate Part B payments for services and medical supplies.” Furthermore, the OIG will review HHA billing practices, specifically for the appropriate location of the services provided as payments to HHAs have nearly doubled between 2000 and 2008. Finally, there will be a review of the CMS enrollment process of HHAs to ensure proper enrollment and that those entities enrolled as HHAs are, in fact, HHAs (and not durable medical equipment suppliers, for example).

For more information, please contact the Health Law Partners, P.C. at (248) 996-8510 or (212) 734-0128 or visit the HLP website.