Be A Thorough Housekeeper
Posted on January 11, 2012 in Featured-writers Newswire
by Tom Boyd, Principal, Boyd & Nicholas
Recently an industry list serve had much discussion of an agency having to pay unemployment insurance benefits to a RN employee who was fired for falsifying the clinical notes. They reported that fact to their state employment office but were still charged for the unemployment claim.
We had a client who fired their contracted PT because she was having some of her visits done by her cousin who was a PT assistant and licensed in another state. The client did not bill Medicare for any of her visits.
In both of the above cases the agency properly fired the caregiver and did not bill for the services the caregiver had provided.
The agency should also check out the employee and the independent contractor on the Office of Inspector General exclusions list, http://exclusions.oig.hhs.gov/ .
“No program payment will be made for anything that an excluded person furnishes, orders, or prescribes. This payment prohibition applies to the excluded person, anyone who employs or contracts with the excluded person, any hospital or other provider for which the excluded person provides services, and anyone else.” (OIG)
The list is updated monthly and every provider should be checking all their employees and contractors upon hiring and on a regular basis thereafter. (See http://oig.hhs.gov/newsroom/video/2011/heat_modules.asp for 4 ½ minute video if wanting more information.)
Why stop there? I suggest that both parties should also:
1) Report the matter to the caregiver’s license board
2) Report the matter to CMS
3) Report the matter to Medicaid
4) Report the matter to the local authorities as criminal acts
The caregivers who were terminated will go to work for other health care providers. They likely will continue their illegal practices. Their practices may cause health problems or complications and even death for the patients they treat.
And If I was a successor employer and found myself sued for malpractice or investigated I would look back at the history of the caregiver and involve former employers to share the responsibility, the blame and the costs.
When engaged in house cleaning you don’t sweep the dirt under the rug (so my wife tells me).
©2011 Tom Boyd. All rights reserved.
About the Author:
Tom Boyd confesses to over 1/3 of a century with Medicare reimbursement starting with the dark side as a Medicare Auditor. Known as the “mad hatter” of cost reports he is an expert on cost reimbursement and other dinosaurs and may be the only person in the country to miss home health cost reimbursement.
He is the overworked chairperson of the NAHC/HHFMA task force committee on the HHA cost report and an often frustrated and beaten member of the U.S. Chess Federation. Mr. Boyd has spoken on home health financial and compliance issues before NAHC, NHPCO and more than twenty state and regional home health care associations.
Tom has a BA in management from Sonoma State University and a MBA from St. Mary’s College of California. A home health consultant since 1989 Tom’s goals are to keep at it until he gets it right. Visit www.boydandnicholas.com or contact Tom at tboyd@boydandnicholas.com
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