Increased Scrutiny via HEAT, ZPICs, and Look for More from Fiscal Intermediary

While the cuts for Medicare home health from the Affordable Care Act have gotten most of our attention over the past months, increased scrutiny by the Federal Government is a much greater immediate threat to home health providers that focus on Medicare patients. The Health Care Fraud Prevention and Enforcement Action Team (HEAT) has been active in the Baton Rouge area, having arrested 31 people on July 16, 2010. One has plead guilty and four others are due to go to trial this coming week. These defendants have been accused of ‘recruiting’ Medicare patients, illegally sharing Medicare numbers with providers who in turn found physicians, four of whom have been indicted, to sign orders.

The Zone Program Integrity Contractor (ZPIC) for Louisiana, AdvanceMed, has been active in Louisiana in recent weeks. HCLA has information that providers for care at home have had requests for ZPIC audits in both the Monroe and New Orleans areas. AdvanceMed was recently cleared to get active after a delay as a result of a legal challenge by another company. Other ZPICs have already been very active in Texas and Oklahoma. Expect to see much more activity from the ZPIC in Louisiana. Their website indicates they now have an office in Baton Rouge. (AdvanceMed’s Program Director, Curtis Watkins, has agreed to speak at the HCLA annual meeting on November 3rd in Baton Rouge.)

Providers are likely to see more review activity from our fiscal intermediary. The increased activity from National Government Services (NGS), particularly in Michigan, has some industry analysts predicting the other RHHIs will be likely to follow suit soon. Those of us who were around to experience BBA ’97 know that the industry was not only squeezed by the changes in the payment system but also had significant denials as a result of intermediary review of documentation that was deemed insufficient and overpayments providers were not able to repay. Considering the increased conversation about physical therapy utilization since the Senate Finance and Securities and Exchange inquiries industry insiders expect therapy to be a big area of interest for Palmetto GBA and the other intermediaries.

Lastly, this week Amedisys received a request for information from the Department of Justice asking for claims information and other business documents dating back to 2003. Amedisys has been the largest home health provider in the nation and predicated revenue of $1.63 to $1.65 billion this year. While the business models of providers across the nation vary greatly from Amedisys, the increased scrutiny of Amedisys will almost certainly result in a more conservative approach from all providers and greater attention being paid to our compliance plans.

Wondering if your bases are covered?  Take advantage of HCLA’s Back to Basics workshops being offered in seven cities across the state October 11-19.

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