Audit Reform in Washington

What is your reaction when you’re notified of a Medicare audit? Does your blood pressure increase? Do your hands get sweaty and your shoulders slump? Are you thinking, “Not again,” “How can I afford to fight this?” or “How can I afford not to?” I don’t know if it’s good news or bad news that you’re not alone. On one hand, it would be terrible to feel singled out and fighting a solitary battle against the audit beast. But on the other hand, Medicare audits of every sort have gotten completely out of control. The health care industry as a whole has realized that every sector must join together in order for any of us to get the necessary changes made. The American Association for Homecare has already met with other national associations regarding audits. They include the American Academy of Physician Assistants, American Association of Nurse Practitioners, American Hospital Association, American Orthotic & Prosthetic Association and National Association for Homecare. We’ve had good, productive discussions and we anticipate that we’ll get further faster by collaborating on both the legislative and regulatory fronts than we will by going it alone. In the Senate, the Finance Committee has jurisdiction over Medicare audits, and AAHomecare is working with the committee to address our members’ concerns. It will be interesting to see what, if anything, changes after Chairman Max Baucus (D-MT) steps down in order to assume his new role as ambassador to China and Sen. Ron Wyden (D-OR) assumes the chairmanship. In the meantime, the Association has provided the committee with recommendations for reform that we believe will protect honest providers while rooting out the few real criminals who have given us all a bad name. AAHomecare also plans to work with key members of the House and Senate on legislation. When they’re not working with members, the Association’s regulatory staff is focused on reaching out to the many different offices and agencies that influence audit policy. One of them is the Government Accountability Office (GAO). The GAO began researching problems with pre- and post-payment audits last fall. When AAHomecare met with them, we discussed the lack of transparency in denials, the error rate, audit and appeals process issues and the urgent need for the Centers for Medicare and Medicaid Services. The meeting was very productive, and the Association has provided the GAO with follow-up information. An office that has recently taken a highly controversial action is the Office of Medicare Hearings and Appeals (OMHA). OMHA’s announcement that they would delay assigning provider appeals to administrative law judges for up to two years drew an immediate and deafening reaction from the entire range of providers. Interestingly, even the Medicare auditors and the think tanks that support them were outraged, although for completely different reasons. The Association attended a public meeting set up by OMHA after the backlash began, sent a letter to Department of Health and Human Services Secretary Kathleen Sibelius that included several suggestions for reform and has been keeping on top of developments as they occur. While AAHomecare leads the charge for audit reform in Washington, it’s important for providers to get out ahead of audits as much as possible. This means taking advantage of all of the tools at your disposal to make your claims cleaner and less likely to be denied when audited. AAHomecare is a good place to start. The Association’s Regulatory Council has created a free audit tracking spreadsheet and five detailed checklists that will help your staff get through the order processing steps the right way, with the right documentation. If you provide diabetic supplies, enteral nutrition, hospital beds, oxygen or PAP supplies, consider downloading a free tracking spreadsheet and checklist from aahomecare.org as soon as possible. And don’t forget that AAHomecare gives you direct access to some of the best regulatory talent in the industry. You can take webinars on different topics related to audits, get advice from members of the Association’s network of independent consultants and send in details of your audit problems to our dedicated address, auditproblems@aahomecare.org. Association members can also call our staff regulatory experts for assistance. If you’re not a member yet, now is the time to join so that you can take full advantage of these benefits.