The best defense is documentation.

Agencies rely on documentation as audit fears spike


The buzz in the home health and hospice industry is that government audits are ramping up. The Centers for Medicare & Medicaid Services are sending out more Zone Program Integrity Contractors and Recovery Audit Contractors to look for evidence of noncompliance. ZPIC audits are especially worrisome – “the most feared type of Medicare auditor” – as they are tasked with investigating suspected fraud and are able to pursue civil or criminal prosecution against suspected agencies, as Home Health Care News explained.

Innocents could stand accused
In some cases, small mistakes in documentation can cause otherwise innocent agencies to be implicated in fraud. MedPro Health Providers, a home health agency in Chicago that was recently named the best small workplace by the Chicago Tribune, is dealing with one such nightmare right now, according to HHCN. A ZPIC audited the agency and then alleged it had made improper payments, in response halting its Medicare reimbursements. MedPro’s owner is suing the contractor for failing to properly review the extensive documents it sent that rebutted the allegations.

“The consequences of even honest mistakes can be dire.”

However, damage has already been done, with hundreds of patients discharged and staff let go. MedPro’s lawyer estimates that 40 other agencies also may have suffered “unfair audit practices” by ZPICs. Those agencies may join the lawsuit.

“[With an audit], you feel a little scare or threatened,” said the owner of MedPro, Rizaldy Villasenor, in an interview with HHCN. “Right now, it’s anger that I am feeling …. The worst thing is letting the team go because of this. If I’m going to close the company, I say it won’t be this way.”

Stay vigilant
When it comes to defending against audits and fraud allegations, documentation is key. Villasenor was able to send detailed records and materials supporting his claim that MedPro is in the clear, and the ZPIC’s alleged failure to follow correct due process when reviewing his rebuttal statements has enabled Villasenor to fight back with a lawsuit.

Agencies should use interoperable EMRs that support comprehensive documentation of all care activities, from reporting to follow-up. This way, the risk of important information falling through the cracks is reduced. Agencies ensure they have all their activities thoroughly documented and detailed, so that in the event of a ZPIC or RAC audit, they have the relevant information ready as proof of compliance.

As they say, the best defense is a good offense – and in the homecare segment, this means having ample and robust documentation protocols in place well before even the first sniff of an audit. Thornberry’s NDoc solution was designed to ensure regulatory compliance and defend against accusations of fraud. Contact the team today to learn how NDoc can help your agency protect itself and its patients.