Manatt Health Partner Randi Seigel and Associate Krusheeta Patel co-authored an article for Compliance Today examining the current risk areas certain post-acute care (PAC) providers face when they serve Medicare and Medicaid beneficiaries and recommending risk mitigation activities.
In the article, the authors explain the history of government scrutiny of these PAC providers, including skilled nursing facilities (SNFs), home health agencies (HHAs), and hospice providers. They continue by detailing the specific risk areas, which “generally relate to patients or residents not meeting the Medicare eligibility criteria, providing medically unnecessary services, and billing for services not provided,” as well as issues surrounding relationships with referral sources.
The authors then provide suggestions for these PAC providers to establish strong compliance programs in order to mitigate risks and decrease the likelihood of facing False Claims Act (FCA) liability. “PAC providers should regularly evaluate their intake and operational programs to ensure they have adequate controls in place to assess a patient’s eligibility for admission and the level and type of services being provided,” the authors said. They concluded with an assessment of recent government activity related to these risk areas in addition to where they anticipate ongoing or increased scrutiny in the future.
Read the full Compliance Today article here.