The Office of Inspector General (OIG) announced that it’ll audit telehealth home health services. This has been labeled the HHA Telehealth Project. It expects to complete the audit in FY2022. What does this mean for you and your agency?
HHA Telehealth Services: What’s Included
In response to the COVID-19 pandemic, CMS issued 1135 waivers that temporarily modified or waived Medicare requirements to ensure care could be easily provided and properly reimbursed. As part of these waivers, home health agencies can provide services to patients using telecommunications technology within the 30-day period of care. Services must be part of the patient’s plan of care. These telehealth visits are not intended to replace in-person visits as ordered on the plan of care. However, only in-person visits can be reported on the home health claim.
As part of the 2021 home health final rule released in November 2020, home health agencies can continue telehealth visits. But, only as long as provisions are included in the plan of care. The use of telehealth technology must be tied to the patient-specific needs as identified in the comprehensive assessment.
CMS doesn’t require a description of how telehealth will help achieve the goals outlined in the plan of care. However, documentation in the medical record must explain how it would help facilitate treatment outcomes.
CMS further states that telehealth visits cannot be a substitute for in-person visits ordered on the plan of care. Also, they cannot be considered a visit for the purpose of patient eligibility or reimbursement. However, telehealth technology can be reported as an allowable administrative cost on their cost report.
CMS also recognizes that the use of technology may result in care efficiencies. And, this could affect frequencies and types of in-person visits as ordered on the plan of care.
HHA Telehealth Project
It states, “We will evaluate home health services provided by agencies during the COVID-19 public health emergency to determine which types of skilled services were furnished via telehealth, and whether those services were administered and billed in accordance with Medicare requirements.” The agency went on to say, “We will report as overpayments any services that were improperly billed (and) will make appropriate recommendations to CMS based on the results of our review.”
How will the audit impact home health? The biggest likelihood is that CMS could change its view on telehealth, particularly regarding efficiency, abuse, and waste. In addition, the audit will likely help shape future policy regarding telecommunications technology in post-acute care.
How to Prepare
The intent of the HHA Telehealth Project is to determine if agencies appropriately billed for services. While we don’t know how many agencies will be audited, as a best practice, all home health agencies, whether you offer(ed) telehealth services or not, should ensure good, solid, accurate clinical documentation. Take the time now to review of your documentation from the past year and make sure it’s on point.
In reality, good documentation is ALWAYS important, not just when there’s a potential for audit. Let’s face it, there’s always a potential. If you don’t already have a strict review process in place, put one in place now. If you need help with documentation review, then consider getting some. With our home health coding services, our experts complete a thorough review of documentation to ensure accurate, complete, supportive documentation and proper coding for compliance, reimbursement, and reporting.