The Centers for Medicare and Medicaid Services (“CMS”) is implementing a new pre-claim review process for home health claims in five (5) states, including Florida. Other affected states are Illinois, Texas, Michigan, and Massachusetts. CMS’ stated goal is to make sure home health services are medically necessary without delaying or disrupting patient care or access. The pre-claim review will begin in Florida no earlier than October 1, 2016 and the other states will be phased in during 2016 and 2017.
CMS claims this is necessary to help home health agencies avoid errors and to protect tax payer funds from fraud and abuse. In 2015, home health claims had an improper payment rate of 59%, mostly because of insufficient documentation. CMS also cites significant amounts of fraud in the home health industry in Florida and other states. CMS states that they would like to get away from their “pay and chase” approach where claims are paid and then recouped for fraud or error. This pre-claim review approach would focus on preventing fraud and mistakes before the claims are paid. In a parallel effort to fight fraud, on July 29, 2016, CMS announced that it is extending for six (6) months the temporary provider enrollment moratoria for home health agencies in Florida, Texas, Illinois, and Michigan and expanding the moratorium statewide in each of those states.
Follow the link to read more of our Client Alert article, “Medicare Home Health Payment Update: Florida and Other States are Required to Submit Their Home Health Claims for Pre-Claim Review“, authored by Shumaker, Loop & Kendrick, LLP partner Erin Aebel and associate Rachel Goodman.