Upcoming CHHA EPS Audits

The Department of Health (DOH) posted on June 9^th a Dear Administrator Letter on upcoming audits on the Certified Home Health Agencies (CHHAs) Episodic Payment System (EPS). According to the DAL, a review of the CHHA EPS found that Medicaid overpayments were made to a number of CHHAs. The identified overpayments included:

1. Improper use of discharge code when a Medicaid recipient is transferred to a Managed Long Term Care (MLTC) plan;
2. CHHA provider paid for multiple episodic payments within 60 days; and
3. Improper use of discharge code when a Medicaid recipient subsequently obtains services from a different CHHA.

DOH stated that these claims are not in compliance with the Billing Guidelines dated April 9, 2013. The audit period includes claims paid from May 1, 2013 through Dec. 31, 2016.

You may recall the February 2017 issue of the New York State Medicaid Update, which stated that the New York State Office of the Medicaid Inspector General (OMIG) would be issuing audit reports. The February issue identified similar reasons for overpayments:

1. Payment for full episodic payment instead of pro-rated episodic payment when the recipient was transferred into a Managed Long Term Care Plan within 60 days of episode;
2. Payment for multiple episodic payments within 60 days of episode; and
3. Payment to two separate CHHA providers for the same recipient within 60 days of episode.

Please note that the February Medicaid Update stated that OMIG will seek to recover all inappropriate payments made to providers.

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