A recent OIG report, “Limited Oversight of Home Health Agency OASIS Data,” examined HHA compliance with Outcome and Assessment Information Set (OASIS) data reporting requirements. OASIS data are used in Medicare payment policy, quality measures, consumer information on the Home Health Compare web site, and state surveys. According to the OIG, HHAs did not submit required OASIS data for 6% percent of claims in 2009, representing over $1 billion in Medicare payments, and 15% of reports were submitted late. While the Deficit Reduction Act imposes a 2% market basket payment reduction if an HHA fails to submit OASIS data, only 199 HHAs were thus penalized from 2007 through 2010. The OIG also found shortcomings in state and CMS oversight of OASIS data. The OIG recommends that CMS: (1) apply the 2% payment reduction to all HHAs that failed to submit OASIS data; (2) take enforcement action regarding late submission of OASIS data; and (3) develop guidelines for state review of OASIS data (CMS concurred with the first recommendation). Another new report, “Documentation of Coverage Requirements for Medicare Home Health Claims,” reviewed the medical necessity of HHA services. According to the OIG, the 84% increase in Medicare home health spending from 2000 to 2007 raises concerns about the potential for improper payments due to fraud and abuse. Based on a review of 495 beneficiaries’ medical records, the OIG found that in 2008, 98% of beneficiaries reviewed met the homebound requirement, needed skilled nursing care or therapy services, and were under the care of a physician. Nevertheless, 22% of claims were in error because services were not medically necessary or claims were coded inaccurately, resulting in $432 million in improper Medicare payments. The OIG intends to continue to monitor Medicare home health claims to determine whether services are appropriate and merit payment. Finally, the OIG has issued a report entitled “Intermediate Sanctions for Noncompliant Home Health Agencies.” The report reviews the status of implementation of an Omnibus Budget Reconciliation Act of 1987 provision mandating intermediate sanctions, such as civil money penalties, payment suspension, and appointment of temporary management, to promote compliance with Medicare conditions of participation. After more than 20 years, CMS has not implemented such sanctions, although CMS states that it anticipates publishing a proposed rule by September 2012. The OIG continues to recommend that CMS make implementation a high priority.