Home Health News

Now is a good time to determine your hospice’s level of risk exposure  to overpayment recoupment from your RAC. Although the RACs have not kicked in yet and may not for several more months, conducting an assessment now can give you a better sense of how vulnerable your hospice might be and how much you need or do not need to be worrying about the RACs.   It can also help in the ongoing challenge of safeguarding against ADR claim denials and unsuccessful appeals.

Here are some considerations for assessing your risk level:

1. Who will do the assessment?
   1. Do you have adequate internal resources with appropriate tools to review a sample of your hospice’s clinical records to ensure forms are valid, signed and timely and that documentation supports the eligibility of each patient for each day on service and for every level of care provided?
   2. Do you need to retain outside clinical consultants to provide expert and objective clinical record reviews to help identify risk exposure and opportunities for improvement?
2. Do you need to retain counsel to protect findings under attorney-client privilege?
   1. This is usually a good idea if you retain outside consultants and have concerns about what might be discovered during an assessment.
3. How far back in time should you review?
   1. It is usually best to start with where you are currently – with active patients and preferably for time frames for which claims have not yet been submitted. If problematic issues are discovered you can then determine (perhaps with the advice of counsel) how much farther back in time you might need to go.
4. What do you do with the results of the audit?
   1. If your findings indicate the possibility that your hospice has been overpaid for claims it has submitted (for example, if documentation does not support patient eligibility) there is the possibility you might be in a voluntary disclosure situation. If that is the case, retain counsel and get legal advice before you do anything else.
   2. If the findings are of concern but do not clearly indicate an overpayment situation, use the findings to identify opportunities for improvement. For example, what needs to be done to ensure members of the IDG have the tools, resources and training they need to accurately and thoroughly document patient eligibility?

Once an assessment of risk is conducted, you will have a better idea of how much you should be worrying about the RACs. More importantly, you will be able to develop a concrete action plan to strengthen staff assessment and documentation skills and ongoing auditing and monitoring activities to ensure your level of risk is minimized.