Cath Lab Digest

In an effort to better understand actual physicians- practices in prescribing, certifying, and monitoring Medicare home health services within the context of the CMS' expectations, the OIG mailed 600 questionnaires in 2000 to physicians who regularly signed Medicare home health plans of care (POC). Nearly all the physicians (97%) reported they had some familiarity with most of the patients for whom they sign a home health POC. Most stated they were involved in identifying the specific home care services their patients needed, but more than half stated that they worked jointly with the HHAs or hospital staff to make these determinations.

Not surprising, perhaps, is that many physicians reported they did not have a clear understanding of key Medicare rules and regulations. For example, 38% said they were unclear on what Medicare considered "homebound" - a crucial coverage criteria for home health care. Even though many knew what CMS expected of them, more felt that realistically, they were unable to provide the level of required oversight for Medicare home health patients. Of the respondents, 83% stated they believed that CMS expected them to ensure that only medically necessary services were on the POC, but only 48% said they could actually do so. Even more surprising was that 60% of the physicians stated they had never heard of Medicare HH PPS, which became effective October 1, 2000. This lack of information may be due, in part, to the timing of the survey, as it was conducted during the last 6 months of 2000, shortly after HH PPS was implemented. Nonetheless, the finding is disturbing.

About 7 years ago, in an effort to encourage physician involvement, Medicare created a way to pay physicians for their time and expertise involved in overseeing POCs for home health patients. In a review of claims data, CMS found that less than 3% of the total healthcare claims showed evidence that physicians had actually billed for the POC oversight payment. More recently, a payment was extended to physicians that covered their time and expertise required for POC certification and recertification. Once again, a review of claims data showed that less than 5% of the physicians billed for these payments. This information indicates that physicians show little willingness to bill for these payments for the services they provide to Medicare home health patients. When asked why, physicians surveyed stated that too much paperwork was involved in submitting the claim and that the payment amount was not high enough to make the effort worthwhile or financially attractive.

Increased Burden on Home Health Agencies

According to the American Association for Homecare and the National Association for Home Care,⁴ home health agencies have recently incurred a number of additional costs simultaneous to PPS. These include: OASIS, higher costs for nurse and therapist recruitment and retention, the potential for electronic private transactions, OSHA bloodborne pathogen and needlestick requirements, significantly higher cost for liability and employee health insurance, and Limited English Proficiency and Culturally and Linguistically Appropriate Services standards. Many other agencies continue to struggle with extended repayment plans to pay off their interim payment system (IPS) overpayments.