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Hello!

Welcome to the August 2010 issue of THE PATHFINDER.

This newsletter is focused on compliance...with good reason...ZPICs and RACs.  Keeping in mind that both RACs and ZPICs are designed by the federal government to "find and prevent waste, fraud and abuse in Medicare," we find we are in a very difficult period for providers.

By way of an introduction - CMS contracts with RACs to identify improper payments of Medicare Part A and Part B claims. RACs conduct post payment reviews to identify over payments and under payments and recoup any over payments they identify. RACs receive payment based on the amount of improper payments identified. 

ZPICs look at billing trends and patterns, and focus on providers whose billings for Medicare services are higher than the majority of providers in the community (e.g. their peers).  ZPICs are responsible for conducting fraud investigations including data analysis, coverage and coding determinations and making referrals to law enforcement agencies such as the FBI.

In addition, the home health listserv has had a strong ongoing discussion regarding ZPIC and RAC audits over the past month.  With a strong interest by all home health and hospice agencies, I have gathered three excellent articles for you this month. 

The first article is a blog entry from Reginald Hislop, entitled "Compliance, the Courts and a Risk Reminder.". Reg is a prolific writer of articles, research papers and an enthusiastic blog writer.  I find his blog entries detailed, and thorough with well thought out comments.

The second is "Hospice or Home Health - Which Is More Vulnerable to Recovery Audit Contractors?" written by Richard  Chesney.  Many of you may know Rich as he is the "Guru" of Medicare data reports.  He is an excellent resource for agencies who are trying to focus their efforts for growth.

Our third resource article for you is written by Elizabeth Hogue, Esq., "Preparing For Audits - ZPIC Audits."  Ms. Hogue, a well-known healthcare attorney, gives practical advice on how to prepare your agency for ZPIC audits by "beefing up"documentation in areas such as homebound status.

As I write this I am out on assignment with my team completing a compliance audit on multiple locations at the request of the ownership of a multi-state Midwest agency.  They are to be complimented for taking a pro-active approach to assess their own status.

With just a few weeks of summer left, take time for your most favorite out of door activities; relieve your stress by laughing with friends.  "Our five senses are not enough for ideal living. We need to use our sixth sense: our sense of humor. Humor isn't about merely telling jokes; it's the way we view the world. We can be sincere about life without taking it so seriously." Chuck Gallozzi   

If we can provide you with any assistance, please do not hesitate to contact us.

COMPLIANCE, THE COURTS AND A RISK REMINDER
A Blog Entry
By Reginald Hislop

In previous posts I've written about the need for providers in all industry sectors to fully understand the compliance and legal risks that are inherent to the appropriate industry sector, as well as to health care today in general.  As someone who has been immersed in health care operations and health policy for the past quarter century, I can honestly say that I have not seen a period more perilous for providers and quite frankly, I perceiver that it will remain risky and perhaps escalate in the near future.

To read more, please click here

HOSPICE OR HOME HEALTH - WHICH IS MORE VULNERABLE TO RECOVERY AUDIT CONTRACTORS  
By Rich Chesney, Healthcare Market Resources, Inc.  

Recovery Audit Contractors (RACs) are economic beings - they'll go where the easiest money is foirst.  This month, we take a look at the industry factors that indicate why hospices are vulnerable to RACs companre to home health businesses.  Plus, we provide important actions hospices should take now to prepare for a RAC review.  

To continue this article, click here.

PREPARING FOR AUDITS - ZPIC AUDITS
By Elizabeth Hogue, Esq.  

The Centers for Medicare and Medicaid Servicew (CMS) are now conducting ZPIC audits.  ZPICs are conducted by Zone Program Integrity Contractors.  Unlike RAC audits that target identification of overpayment and CERT audits that attempt to pinpoint improper payments, ZPIC audits focus on fraud in the Medicare Program.  This means that ZPIC contractors can audit the integrity of all Medicare claims, both pre- and post- payment.

 To read further...

WE ARE PLEASED TO ANNOUNCE A NEW SERVICE
Accreditation Commission for Health Care
Beth Carpenter and Associates is proud to announce the addition of a new service for its clients!  We are now able to support your efforts to achieve accreditation through Accreditation Commission for Health Care (ACHC) whether you are a new or existing agency - home health, hospice or private duty.  

To assist you in your efforts to reach and maintain deemed status for Home Health and Hospice agencies as well as accreditation as a Private Duty Nursing and/or Private Duty Aide organization, the following are a sample of potential services currently available through Beth Carpenter and Associates:
• Assistance in preparation of the ACHC Application and the Preliminary Evidence Report (PER).
• Review of  your Application and PER prior to submission to ACHC.
• Assistance with any revisions to the PER requested by ACHC following initial submission.
• Training and instruction to administration and staff to prepare for an on-site ACHC survey.
• Assistance in creating a Plan of Correction, if necessary, following an on-site ACHC survey.

Subsequent to successful accreditation, we are available to work with your agency to continue compliance with the ACHC standards.  For further information, call 847-382-1035 or e-mail bcarpenter@bethcarpenterandassociates.com.

Beth Carpenter
Beth Carpenter and Associates 847-382-1035
bcarpenter@bethcarpenterandassociates.com

Beth Carpenter and Associates has earned a reputation as a company with deep industry experience and one that works closely with its clients to identify solutions that meet their business goals and strategic objectives.  We do not simply advise.  We partner with our customers to implement the solution and ensure its success.

Sincerely, Beth Carpenter

ARE YOU ON THE RIGHT PATH?
Since 1995 Beth Carpenter and Associates has provided its real-world experience to the management of healthcare companies, especially those  organizations with a focus on home health, hospice and private duty, in the areas of operations, clinical services, sales and marketing.  We work with management to identify the strategic direction of the organization and implement the necessary changes that allow health care providers to move forward in today's environment.

We help you choose the right path to success and then we walk it with you.