Surveys: Supplying Patient Lists Could be a Thing of the Past

A recent Inspector General’s (IG) report outlines the biggest and sometimes most conflicting item provided during a survey: the patient list. Agencies typically provide a list of all patients or a select list based on specific state guidelines. However, with this recent report, surveyors might arrive on site with a list of specific patients already selected.

In some cases of reported complaints or potential neglect or abuse, surveyors already have a good idea as to which patients will need to be surveyed. Under the new recommendations from the Inspector General, surveyors would use this same tactic when conducting routine surveys for state licensure.

One important aspect to note on this is that the report does not indicate if accredited agencies would be included. CHAP, Joint Commission, and ACHC accredited agencies who face tougher standards typically don’t get surveyed by each state unless a complaint is lodged. But these accrediting bodies also may not have access to the data that state surveyors do.

The IG sampled 28 home health agencies’ patient lists or rosters for surveys. The IG focused solely on Medicare patients, as most surveyors do unless the agency is heavily populated by Medicaid patients.

Of the 28 agency patient lists, nearly one third of them were incomplete. The patient lists were compared against OASIS submissions. In one extreme case, 90% of the patients who were admitted to the agency were removed from the list provided to the surveyors. States that were sampled include high-risk, known areas for prevalent fraud.

The IG has made several recommendations to improve the accuracy of the surveying process. While this might not seem advantageous to agencies, you always have to revert to the mantra, if you aren’t doing anything wrong, what do you have to hide? One of the recommendations is for the surveyors to preselect patients to survey from OASIS data. The alternative method is for surveyors to use claim data from the FISS DDE system.

Both of these methods could improve the integrity of the home health system and help relieve some of the negative tones that are often associated with the industry. However, some agencies that are compliant may get caught up in a situation in which data doesn’t always match reality. Lists provided by surveyors will be dependent on being run properly for the correct survey period and must only include those claims that surveyors are expected to review.

For instance, there is a gray area with Medicare Advantage claims. While OASIS data is submitted, do these patients get included as their services are paid indirectly from Medicare to an insurance carrier and then onto the agency? Patient lists that are derived from FISS DDE entries might be the more reliable source. Rather than relying on clinical data, the surveyors can pull patient demographics, the episodes in which care was provided, and total reimbursement.

Combining the two methods and relying on each rather than using one method or the other will likely give surveyors much more information to work with. For many agencies this shouldn’t be a problem. But for agencies who have questionable billing practices or over utilization, these could be just some of the many targets that the data could identify.

Much of the new focus on data driven survey analysis comes from CMS’ intent to utilize more data and information already at its fingertips. The Trump administration has focused on using data to drive more progress towards efficiency and less waste. The IG’s report and analysis is just the beginning of in-depth reviews across all areas under the purview of CMS’s authority. In the coming months, we can expect to see more reports and analysis on how providers utilize government resources and recommendations on how efficiencies can be obtained.

To read the full IG report, click here.

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