Actions to Ensure Home Health Regulatory Compliance

Meet CMS Requirements and Commit to Quality Patient Care

Managing ever changing CMS requirements can be a huge burden on home health agencies. Implementing a comprehensive compliance program not only ensures that you meet CMS requirements, but also establishes your commitment to higher ethical standards and quality patient care.

According to the OIG Compliance Program Guidance for Home Health Agencies, there are seven essential actions that should be taken to ensure a successful home health compliance program.

  1. Develop written standards of conduct, policies, and procedures.
    This type of communication should reflect your agency’s obligation to regulatory compliance and address areas of potential fraud. Employees should agree to adhere to these standards, and performance evaluations should include an evaluation of adherence.
  2. Designate a compliance officer and/or compliance committee.
    Charged with the responsibility of operating and monitoring the compliance program, the compliance officer/committee should be up to date on changing compliance laws and ensure that policies are being followed.
  3. Develop and implement regular, effective education and training programs.
    Training should be mandatory and conducted on a regular basis. Your agency’s compliance program structure, along with pertinent laws and regulations, should be discussed. Strong emphasis should be placed on the importance of regulatory compliance across team functions.
  4. Create and maintain a standardized reporting system for complaints.
    Agencies should create a method of submitting regulatory breaches or complaints to the compliance officer and/or committee. This could be a third party hotline, suggestion box, or other form of safeguarded communication. The submission method should be anonymous to protect complainants.
  5. Enforce standards through disciplinary guidelines.
    Provide guidance regarding disciplinary action for employees who fail to comply with your standards of conduct, policies, and procedures. Your compliance program should include a written policy identifying the degrees of disciplinary actions that may be imposed on non-compliant employees.
  6. Monitor compliance.
    Utilize internal or external audits and/or other evaluation techniques on a regular basis to monitor compliance and identify problem areas. At a minimum, audits should focus on your compliance with laws governing kickback arrangements, physician self-referral prohibition, claim development and submission, reimbursement, cost reporting, and marketing.
  7. Respond to detected offenses and develop corrective action plans.
    Home health agencies should have a policy in place for the investigation of alleged misconduct. Detected but uncorrected misconduct threatens your agency’s reputation, reimbursement, and possibly licensure.

HEALTHCAREfirst offers a number of products and services to help you ensure regulatory compliance. For more information, contact us today.

May 19, 2016

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