February 19, 2013

The Office of the Medicaid Inspector General (OMIG) has just posted the final audit protocols for Certified Home Health Agencies (CHHAs), which are effective Feb. 14, 2013. While LeadingAge NY and other associations were successful in advocating for some changes, other areas of concern remain.

The CHHA protocols cover 34 different areas, encompassing a multitude of laws, regulations and provider manual requirements. They specifically relate to services provided prior to Dec. 31, 2010, which pre-dates the inception of episodic payments, other MRT initiatives and the tropical storms/hurricanes. LeadingAge NY and other associations have been in active discussions with the OMIG since December 2012 on draft versions of the protocols. Our concerns were outlined in a joint association memo sent last month. We have had several meetings and communications with OMIG to identify specific concerns and, yet, the protocols have not been revised from a January draft version.

LeadingAge NY plans to closely monitor the ensuing audits, and bring any concerns to the OMIG's attention. OMIG officials have agreed to provide an educational forum for CHHA providers to review the protocols and answer their questions. LeadingAge NY thanks those members that provided us with feedback during this process.

Contact: Cheryl Udell,  cudell@leadingageny.org, 518-867-8871