Re-enroll? More audits? What’s it all mean?

When President Clinton declared a moratorium on new home health agencies entering the Medicare program last month, he also promised to double the number of home health agency audits, and to require that all agencies re-enroll every three years so they too must abide by the tougher Medicare regulations in the works. (See special Fax Bulletin on Clinton’s speech to the Service Employees International Union, inserted in this issue.)

However, what exactly this all will entail was unclear to providers as Homecare Quality Management went to press.

The audits the president spoke of, which will double from 900 to 1,800 a year, will be financial audits of home health cost reports conducted by the intermediaries, says Beth Giebelhaus, senior technical advisor for program integrity at the Health Care Financing Administration (HCFA) in Baltimore. Medicare will pay intermediaries $5 million to conduct the extra audits.

As of Sept. 1, all home care providers entering the Medicare program have been required to use the new 855 enrollment form. While HCFA hasn’t quite determined what "re-enrollment" will mean, "it’s obvious that any agencies that have not been enrolled using the 855 will probably have to submit an 855," another HCFA source says. "It’s open to debate how the information on the 855 will be verified [every three years]."

However, the current 855 form may undergo additional changes, so be looking for a "notice of proposed rulemaking" in the Federal Register. One HCFA source says the "tougher new regulations" the president spoke of will result in the creation of two new pages that will be added to the current 855 enrollment form requesting additional information from agencies. Agencies enrolling in the Medicare program, and agencies re-enrolling every three years, will probably be required to fill out the additional pages after Jan. 1, 1998.

Judith Carey, technical assistant in the center of continuing care providers at HCFA, says it will take about 30 days for the 855 forms to be reviewed. Individual states will give providers the new form, and states will tell providers which fiscal intermediary to send the form to when it’s filled out. The 855 will eventually be used for all provider types HCFA deals with.

The "re-enrollment" process will "probably be some type of hybrid of the current enrollment process," Carey says.

"Everyone is concerned that this will add unnecessary cost for agencies that have been following the rules all along," says Cathy Nielsen, RN, CPHQ, vice president of clinical services for In-Home Health in Minnetonka, MN. "As a result of finding agencies that are routinely in compliance, they were going to decrease the number of on-site surveys for those providers. Why would they have to re-enroll then?"