Office of Medicaid (MassHealth) - Review of Hospice Care Billing: HopeHealth Massachusetts, Inc.
September 21, 2017 · Office of Medicaid (MassHealth) · Read the full official report (PDF) ↗ · official site ↗
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“HopeHealth did not always maintain properly completed required documentation for hospice services, and some member files contained inaccurate information.”
Read the plain-English breakdown
This is a state audit of hospice claims that HopeHealth submitted to MassHealth for services from July 1, 2011 through June 30, 2016.
“OSA has conducted an audit of hospice claims paid to HopeHealth Massachusetts, Inc. for the period July 1, 2011 through June 30, 2016.”
The auditor checked whether HopeHealth billed MassHealth only for proper hospice services and kept the required records to back up those bills.
“The purpose of this audit was to determine whether HopeHealth billed MassHealth for appropriate hospice services and whether it documented them in member files in accordance with applicable state laws and regulations.”
Incomplete or inaccurate records make it harder to know whether public healthcare dollars are paying for the right services.
“Without ensuring that it obtains and maintains all required documentation in members’ files, HopeHealth has a higher-than-acceptable risk of providing and billing MassHealth for levels and types of hospice services that may not be medically necessary.”
If you are a taxpayer or MassHealth member, this matters because MassHealth is a major public program serving many Massachusetts residents and using a large share of the state budget.
“Medicaid expenditures represent approximately 39% of the Commonwealth’s total annual budget.”
HopeHealth was told to fix its paperwork process and add checks to make sure member files are complete and accurate.
“HopeHealth should put controls in place to monitor the completion and filing of hospice documentation to ensure that all member files contain complete and accurate information.”
The report is significant because MassHealth paid HopeHealth about $17.5 million for hospice services during the audit period, and the auditor found weaknesses in the records supporting some of those payments.
“During this period, MassHealth paid HopeHealth approximately $17,483,302 to provide hospice services for 611 MassHealth members.”
A Certification of Terminal Illness form is the required doctor paperwork saying the patient is expected to live six months or less if the illness follows its normal course.
“The hospice provider also needs a qualified physician to complete a Certification of Terminal Illness Form certifying that the member is terminally ill and has a life expectancy of six months or less.”
2 figure(s) pending source verification - not shown
What the Auditor checked
- Did not comply Did HopeHealth maintain proper documentation in member files to properly support hospice services it billed for?
What the Auditor found
Why it matters: HopeHealth had a higher-than-acceptable risk of providing and billing MassHealth for hospice services that may not have been medically necessary, and some documentation issues created a potential privacy risk.
Standard: 130 CMR 437.411(C), 130 CMR 437.412(C), and 130 CMR 437.425 require complete hospice certification, election, and clinical record documentation. ( Section 437.411(C) of Title 130 of the Code of Massachusetts Regulations; 130 CMR 437.412(C); 130 CMR 437.425 )
2 recommendations
- HopeHealth should ensure all required CTI Forms, Hospice Election Forms, and Discharge Summary Forms are complete, accurate, compliant with MassHealth regulations, present in each member file, and not commingled with other patients’ information.agency: already implemented
- HopeHealth should implement controls to monitor hospice documentation completion and filing.agency: already implemented
Agency response & Auditor reply
Agency: "Management believes that it has taken appropriate action steps to ensure that all required forms including Certification of Terminal Illness Forms, MassHealth Election Forms, and Discharge Summary Forms are complete, accurate, and compliant with MassHealth regulations and present in each member’s record."
Auditor: "Based on its response, HopeHealth has taken the necessary steps to ensure that its noncompliant medical files have been properly updated to contain complete and accurate CTI Forms, Hospice Election Forms, and Discharge Summary Forms that comply with MassHealth regulations and that it is monitoring these activities on an ongoing basis to ensure that it maintains compliant medical files."
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