Home Health & Hospice

Agency Compliance Plan More Important Than Ever

Homecare Insider, January 17, 2011

With the advent of healthcare reform and the 2011 Prospective Payment System Final Rule, one common thread continues to rear its ugly head: fraud and abuse in the home health industry. Your agency’s plan to prevent fraud and abuse can play a very important role in how you are viewed by regulators and how your agency avoids these risks.

Even with information overload regarding fraud and abuse in the industry, many agencies do not have compliance plans. To start 2011 off right, it is important to establish a plan if your agency doesn’t have one. If agencies choose not to start at ground zero to establish their compliance plan, there are many templates available. However, it’s not as complicated as it sounds. 

An agency compliance plan does not have to be lengthy and full of convoluted language. Here are some tips for beginning development of your plan:

  • The compliance plan should contain a general statement, guidelines for the ethical delivery of care and billing practices, and address staff competency.
  • Many of your agency’s current policies will be part of the compliance plan. Examples can include the confidentiality policy, admission policy, and documentation policy.
  • The compliance plan should include the process for the reporting of and responding to compliance issues.
  • Agencies often overlook the importance of keeping logs of certain activities and these logs should be addressed and included in the compliance plan. For example, agencies should log referrals, admissions, and physician orders. The agency’s referral/admission log should reflect the date of referral, referral source, payer source, physician, date of admission, and if not admitted, the specific reason. This is the minimum amount of information required and agencies should include anything they believe is important. The physician order log should track all orders, including certifications and recertifications. 

Establishing an agency compliance plan is a New Year’s resolution that should be made and kept.