OIG Issues Report on Home Health Payments and OASIS Submissions
March 28, 2014 10:03 AM
The Office of Inspector General (OIG) has issued a report of its audit of home health payments in six New England states concluding that many of the audited claims should be denied payment because the required OASIS had not been submitted to the State survey agency or had not been accepted as submitted.
The OIG found:
The RHHI paid Medicare claims for which HHAs had not submitted the required OASIS data. Of the 100 claims that we sampled, the RHHI made payments totaling $156,722 for 65 claims that should not have been paid. Specifically, 36 claims should not have been paid because the HHAs had not submitted accepted OASIS data at the time of payment, and 29 claims should not have been paid because HHAs had not submitted accepted OASIS data. We estimated that the RHHI made approximately $25.1 million in Medicare overpayments because it did not deny claims that HHAs had submitted without the OASIS data, which is a condition of payment.
Overpayments occurred because HHAs often had inadequate controls for the submission of OASIS data. Furthermore, Medicare payment controls were inadequate to prevent or detect payments to HHAs for claims that were missing accepted OASIS data. Without adequate controls, CMS has a limited ability to prevent payments to HHAs that have not submitted accepted OASIS data.
Under Medicare rules, the submission and acceptance of the OASIS is a condition of payment. Home health agencies are cautioned to evaluate their claim submission systems to ensure that claims are not prematurely submitted prior to the OASIS acceptance.
The OIG is taking a hardline approach in these audits and a similar approach would be expected of Medicare contractors, particularly RACs and ZPICs. While CMS agreed with the OIG recommendation to recover the overpayments that the OIG uncovered, it refused to consider reopening of other claims where late OASIS submission and acceptance had occurred. However, the OIG rarely gives up in these types of matters and the Medicare contractors often pursue any possible overpayments.
The full OIG report is available at here.