Home health surveyors select patients for review using lists supplied by home health agencies (HHAs), but some of the lists are missing information, a new report indicates.

Of the 28 HHA-supplied rosters reviewed by the Department of Health & Human Services’ (HHS) Office of the Inspector General (OIG), nine were incomplete. Each of the incomplete rosters was missing one or more Medicare beneficiaries who were active on the roster date, according to claims data. Two of the nine rosters were missing 10 or more active beneficiaries; one roster was missing more than 150, or almost 90%, of the HHA’s active beneficiaries.

“For one of our selected HHAs, four Medicare beneficiaries were discharged on the roster date, but readmitted to the HHA later in the year,” the report noted. “The beneficiaries did not have other claims that would explain the break in care, such as being admitted to a hospital, a skilled nursing facility (SNF), or another HHA between the discharge and the readmission. These discharges may reflect an intentional effort to avoid surveyor scrutiny of the beneficiaries, rather than appropriate decisions made on the basis of clinical condition and care needs.”

The OIG collected Patient Lists supplied by HHAs that were used by surveyors for recent inspections for selected high-risk HHAs in Florida, Texas and California.

The agency compared the lists to Medicare claims data to identify missing beneficiaries and held interviews with state survey agencies, the Centers for Medicare & Medicaid Services (CMS), and accrediting organizations about the process of conducting HHA surveys and the surveyors’ use of HHA-supplied patient lists.

Some of the patient lists in the review were missing Medicare beneficiaries, and the OIG found surveyors are unable to comprehensively verify how complete the HHA-supplied lists are at the time of the survey.

There are two potential tools, however, for verifying HHA-supplied patient lists: Checking the lists against reports based on Outcome and Assessment Information Set (OASIS) data, and checking the lists against data from home health claims.

Though neither method would allow for comprehensive verification of the patient lists at the time of the survey, those data sources could still be useful tools for CMS and for surveyors, the OIG report argued.

“OASIS data should reflect most of an HHA’s beneficiaries at the time of the survey (i.e., all those except recent admissions), and could thus be used to verify that most, if not all, of an HHA’s beneficiaries are included on the HHA-supplied patient list,” it said. “Additionally, both OASIS data and claims data could be used to comprehensively verify HHA-supplied patient lists retroactively, once all submissions have been received from the HHA.”

Other possible ways to limit HHA list manipulation, according to the surveyors, included:

-Monitoring HHA staff as they retrieve or compile patient lists during unannounced surveys to discourage omitting patients

-Giving surveyors direct access to HHAs’ electronic health records (EHRs) to let surveyors compile patient lists themselves

The OIG had some suggestions of its own for mitigating risk; these included:

-Creating new OASIS-based reports or adapting existing reports for surveyors

-Conducting retrospective reviews using claims data

-Directing surveyors to confirm that patient lists include a subset of active patients

Written by Maggie Flynn