OIG: Home Health Improper Documenation ‘Prevalent’

Insufficient documentation in home health is a primary cause of Medicare fee-for-service improper payments, a new report by the Department of Health and Human Services Office of Inspector General (OIG) has found. The report comes just after a federal audit concluded hospices had improperly billed Medicare by $268 million in 2015.

The report underscored how the U.S. Department of Health and Human Services (HHS) met some of the requirements of the Improper Payments Information Act (IPIA), but failed to fully comply during 2015. OIG conducted a performance audit of HHS’ compliance with improper payment reporting regulations, which require the department to inform the President and Congress on improper payments from HHS agencies. Overall, HHS failed to meet a number of targets.

Under IPIA, the Medicare fee-for-service error rate percentage should not have exceeded 10% in 2015. The rate was 12.9% for the fiscal year.


Home health improper payments and documentation were found to be a big part of the problem.

“HHS documented that insufficient documentation was particularly prevalent for home health claims,” the report findings read.

Improper payment rates for home health claims increased 7.57% in fiscal year 2015 from the year prior. However, increased documentation requirements proving the necessity of home health services may be partially to blame for this jump, according to the findings.


The Centers for Medicare & Medicaid Services (CMS) pledged to improve documentation and addressed OIG concerns over its hospice improper billing rate in its issuance of upcoming hospice payment increases. CMS pledged to continue working on the issue by improving oversight.

“The Office of the Inspector General (OIG) has raised concerns about the potential for hospices to target beneficiaries who have long lengths of stay or certain diagnoses because they may offer the hospices the greatest financial gain,” the CMS FY2017 payment guidance reads. “We continue to communicate and collaborate across CMS to improve monitoring and oversight activities of hospice activities. We expect to analyze more recent hospice claims and cost report data as they become available to determine whether additional regulatory proposals to reform and strengthen the Medicare hospice benefit are warranted.”

The OIG’s latest recommendation urges HHS to “proactively take action” for the upcoming fiscal year by establishing target rates for improper payments. Improved communication between federal payers and providers through increased documentation could help monitor adherence to target rates, the report states.

Written by Amy Baxter

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