In response to recent high profile instances of fraud, waste, and abuse, the Centers for Medicare and Medicaid Services (CMS) released Survey and Certification letter 14-10-HHA on February 4, 2014, extending the moratoria on home health agency enrollment. These moratoria are phase two of the original release in July, 2013 that curtailed the enrollment of any new home health agency in Chicago, IL (Cook, DuPage, Kane, Lake, McHenry, and Will counties) and Miami, FL (Miami-Dade and Monroe counties). CMS reports that these areas were chosen due to high risk for fraud, high utilization, and a disproportionately large number of new providers.
In this new phase, CMS has extended the moratoria in the above areas, and has also added four additional targeted areas - Fort Lauderdale, FL (Broward county), Detroit, MI (Macomb, Monroe, Oakland, Washtenaw, and Wayne counties), Dallas, TX (Collin, Dallas, Denton, Ellis, Kaufman, Rockwell, and Tarrant counties) and Houston, TX (Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller counties).
The moratoria will affect any home health agency located in the above areas that has applied for, or is in the process of obtaining a Medicare provider number, but has not been approved by the Medicare Administrative Contractor (MAC) as of January 30, 2014. In order for a home health agency’s application to be considered complete, CMS requires that the following steps must be fully completed:
- The agency’s initial Medicare certification survey must have been completed
- The second MAC review has been completed
- CMS regional office sent the tie-in notice to the MAC
- The MAC performed a site visit
- The MAC switched the agency’s Provider Enrollment Chain Organization System (PECOS) record to approved
If all of these steps were not completed prior to the implementation date of the moratoria, the agency’s application will be denied. If an organization’s status is denied, they will be notified by the MAC. Once the moratorium is lifted, the agency will need to complete a new enrollment application if it continues to seek a Medicare provider number. In addition, the MAC will deny any application for a branch addition location in the above areas as well. Agencies affected will have the right to appeal by following information found in the denial letter issued by the MAC.
Unfortunately, home health surveys conducted by an accrediting organization in these targeted areas for initial deeming purposes will not be accepted by CMS and will not be accepted as a valid survey during the moratoria. ACHC can continue to process prospective home health agency’s application for accreditation only. For more information, contact your Accreditation Advisor at (855) 937-2242.
Ready for accreditation? Contact ACHC at (855) 937-2242 to learn more.