VNAA Sends Letter to GAO on Home Health and Hospice Audits: High Interest At Annual Meeting
Wednesday, April 17, 2013
by: VNAA Policy Team

Section: Public Policy and Advocacy

On April 5, VNAA sent a letter to the Government Accountability Office (GAO) as a follow up to a February meeting at which VNAA members and staff presented a comprehensive list of concerns regarding Medicare audits on home health and hospice agencies. The letter outlines key concerns of members and provides recommendations for changing the audit process including the need to: 1) Train and provide quality control for auditing staff, 2) Provide transparency, clear requests and a firm timetable for auditors to respond, 3) To ensure that auditing staff receiving clear training and guidance with regard to new legislative/regulatory change, 4) Utilize current data from auditors to better target outliers and reduce administrative burden on small/rural agencies, and 5) Rework the appeal process to address the fact that many of the audit denials are overturned at the Administrative Law Judge level. To read VNAA’s letter to GAO, please click here.
At the VNAA Annual Meeting in Florida, there continued to be a very high level of concern regarding problems with audits – in both a breakout session and the Friday morning Public Policy Forum.  

Congress asked the GAO to prepare two papers with the first paper being an overview of all the different auditors that the Centers for Medicare and Medicaid Services (CMS) is using and a second report that will discuss how well CMS is managing audits. While GAO was instructed to look for post-payment audits only, VNAA has strongly advocated that GAO also address pre-payment audits.

VNAA has been very proactive on audits including: 1) surveying members on specific audit concerns, 2) securing a meeting with GAO, and 3) preparing a comprehensive follow up letter that captured and expanded member concerns. VNAA has also provided numerous educational programming on all aspects of home health and hospice audits.

Next public policy steps include pursuing a meeting with CMS to identify problems and brainstorm solutions as well as continued advocacy with Administration officials and Congress to expand the GAO oversight investigation to include pre-payment audits. 
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