Medicare compliance: Don't wait for a probe
Medicare compliance: Don’t wait for a probe
Tennessee Hospital Association preps members
What should hospital-based home care directors do about the federal government’s fraud and abuse initiatives?
Be prepared, advises the Tennessee Hospital Association’s Mike Dietrich, executive director of the THA’s Home Care Alliance. His organization currently is working on a blueprint that THA member hospitals and their home care agencies can adapt for their own compliance programs.
THA has organized a statewide task force to review member home care agencies’ compliance programs, says Dietrich. From those, the group will develop a "template that we can give to organizations for them to develop their own corporate complaint programs," he says.
And THA, which represents about 95% of all the hospitals in Tennessee, already is conducting seminars for its 154 members, advising administrators what to do when federal investigators accuse them of fraud. THA President Craig Becker, who initiated the seminars, advises, "If you don’t have some kind of compliance program in place, you’d better get one sooner than later. The first step is to have the [hospital or home care] board declare they are going to have a compliance program and start working on it.
"If you show a good-faith effort, it doesn’t stop the letters, but it can help mitigate things when you have to negotiate issues."
Becker and his THA team created a battle plan in May after learning from the U.S. Justice Department that the state’s hospitals were next in line in a federal probe of Medicare billing practices, i.e., overbilling or double-billing for services. But rather than wait for letters from the Justice Department, THA is telling hospitals what to do ahead of time.
In a bulletin sent to members, THA describes the investigation in detail and offers tips:
"When hospitals receive the letters, there will be two key dollar figures. The first is the total financial exposure of your hospital." The second figure, THA tells members, will be the amount the Justice Department will settle for.
So far, none of THA’s home care agencies have been cited in a probe, but Dietrich’s group is taking no chances. THA home care agencies can expect help soon in the form of their own battle plan.
"It’s only theory at this point, but it’s got to happen quick. I think everybody realizes the focus the feds are placing on this. We hope to have everything in place in November," Dietrich says.
In taking a proactive approach, THA "brought all parties together public hospitals, private for profit, not-for-profit, nonprofit, you name it and we began looking at corporate compliance as a whole."
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