OIG Released Report on Home Health Surveys
Tuesday, May 21, 2013
by: VNAA Policy Team

Section: Public Policy and Advocacy

On May 15, the Department of Health and Human Services, Office of Inspector General (OIG) released a report on home health agency (HHA) deficiency citations and the state survey process. 

OIG Findings

Based on the Centers for Medicare and Medicaid Services (CMS) data for 2010 and 2011, OIG reported that 12 percent of HHAs were cited with the more serious condition-level deficiency while 62 percent of HHAs had standard-level deficiencies. Ninety-three percent of agencies with condition-level deficiencies corrected them in the required 90-day timeframe. The remaining 7 percent were given an extension and eventually returned to compliance in an average of 130 days with only a few HHAs either voluntarily leaving or being terminated from Medicare.

On complaints, 15 percent of HHAs had complaints lodged against them with 7 percent resulting in condition-level deficiencies. Nearly all HHAs with complaints corrected the deficiencies. 

Table A-1 of the report provides a state-by-state breakdown of the number and percent of HHAs cited with condition level deficiencies and Table A-2 provides a breakdown of actions taken by accrediting organizations. 
For HHAs with condition-level deficiencies, the most prevalent deficiencies were:
  • noncompliance with acceptance of patients, plan of care, and medical supervision (35 percent);
  • noncompliance with organization, services, and administration (32 percent); and
  • noncompliance with skilled nursing services (27 percent).
The majority of recertification surveys, or 82 percent, were conducted by state agencies, and 18 percent were conducted by accreditation organizations. There is considerable variation in condition-level deficiency citations between states. Nine states agencies did not cite any while eight states agencies cited condition-level deficiencies for 20 percent or more of HHAs. The Joint Commission cited the most condition-level deficiencies of all accreditation organizations. 

The OIG report found that nearly all recertification surveys for HHAs conducted by state survey agencies and accreditation organizations were done in the required 36-month timeframe. For the remaining 2 percent of HHAs, recertification surveys were past the 36-month deadline by a median of three months. 

OIG Recommendations

Intermediate Sanctions: OIG notes that its 2008 report found that many HHAs had the same deficiencies cited during multiple recertification surveys. At that time, OIG recommended that CMS implement intermediate sanctions authorized in 1987. OIG notes that in November 2012, CMS issued a final rule to implement intermediate (or alternative) sanctions for noncompliant HHAs. The first set of sanctions, which will become effective on July 1, 2013, includes temporary management, directed plans of correction and directed in-service training. Two additional sanctions—civil money penalties and suspension of Medicare payments for new patient admissions—will become effective on July 1, 2014.

Surveys: Federal law requires CMS to do “look-behind” surveys of accrediting bodies but does not require the same for state surveys. In this report, OIG recommends that CMS analyze survey data to determine whether it should routinely conduct look-behind surveys for oversight of state agencies. CMS concurred with this recommendation and will work with regional offices to identify states with the greatest need for look-behind surveys.

The OIG report can be found here. 
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