The Department of Health and Human Services, Office of Inspector General, has issued a new Risk Alert focusing on the home health agency (HHA) survey process.  The alert specifically examined whether HHA-supplied patient lists during surveys may omit certain patients from review and thereby present opportunities to conceal fraudulent activity or health and safety violations.

Upon reviewing a small sampling of patient lists from previous surveys, the OIG found that nearly one-third of HHAs had incomplete lists of patients, although the OIG noted that its analysis “cannot speak to the intent of the selected HHAs.”  To reduce the potential vulnerabilities that use of HHA-supplied patient lists presents, the OIG suggested developing patient lists from OASIS-based reports, conducting retrospective reviews of patient lists based on claims data, monitoring HHA staff as they generate patient lists, and confirming through sample staff interviews that patient lists include a subset of active patients served by the sampled staff members.