Home health agency to repay Medicaid overpayment

Staff Report

COLUMBUS — Several employees of a Medicaid provider in Meigs County administered home health aide services even though they had no first aid certification, according to a report released Thursday by Auditor of State Dave Yost.

The findings were among 92 errors auditors identified in a sample of 735 services provided by Elite Home Nursing Services LLC from 2013 through 2014, resulting in Medicaid overpayments totaling $67,760. With interest, the provider owes the Ohio Department of Medicaid $74,006. The provider was paid $694,974 for 6,826 aide and nursing services during the period.

Auditors discovered that five of 32 personal care aides tested never obtained first aid certification during the review period. An additional four aides provided services prior to obtaining first aid certification.

The owner of the agency, formerly known as Ohio Valley Home Nursing Services LLC, told auditors that she assumed the Basic Life Support (BLS) course completed by the aides had included first aid. However, auditors verified that first aid was not part of the BLS course curriculum.

In a response from Elite Home Nursing, Administrator Eddena Smith states, “Elite Home Nursing Services, LLC began serving Meigs, Gallia, Athens and Washington counties January 2013 with the goal then to provide excellent home health services to our underserved community. This continues to be our goal up to the current date 4 years later.”

“The audit reflected our only area of non-compliance is within the provider qualifications, singly the home health aide services. The audit reported that the majority of our overpayment stems from a discrepancy involving first-aid certification. The policy of our agency at that time required all staff providing direct patient care to have Healthcare Provider CPR. With that being said, as an agency, we were under the impression that we were over qualifying our staff with the CPR certification because the state of Ohio requires only first-aide. As a nurse of 19 years, I have taken a CPR course every 2 years, each course contained a first-aid component in addition to basic life support. We truly believed we were over credentialing our home care aides,” Smith stated.

“In addition, as of October 2014, we credentialed one of our staff members to exclusively teach CPR and First Aid to our employees upon hire and every two years to promote continuity and control over course content. Further audits will not result in a noncompliance,” Smith added.

“Mistake or not, these employees weren’t qualified to care for patients,” Auditor Yost said. “Now that the provider is fully aware of the state’s requirements, I trust that she will take every step necessary to remain compliant.”

The review also determined that two of 24 personal care aides tested for compliance with competency evaluation requirements provided services before they completed their evaluations.

In a separate finding, auditors noted that supporting documentation for 14 services lacked legitimate signatures from the recipient or an authorized representative. The recipient signature is required to verify that the service was delivered. Instead, it appeared that the aides who completed the documentation added the recipient’s initials or signature.

Other findings in the report include:

  • The units reimbursed for seven services exceeded those listed on service documentation;
  • No service documentation was available to support two services;
  • Five services were submitted for reimbursement before the provider obtained a physician’s signature on a plan of care to authorize the services; and
  • Two plans of care were signed by a certified nurse practitioner instead of the certifying physician.

“Looking at this survey, I would like the public to take into consideration that this is our initial audit, and the results reflect that our overpayment still remains less than the national average,” continues Smith. “Currently, the national overpayment averages 10% or greater. Elite Home Nursing Services, LLC was able to remain below the national average, despite the fact of being a contemporary agency in an ever-changing and rapid growing industry.”

The audit covers the time period of January 2013 to December 2014, and does not include services provided since that time.

Smith noted in her response that there was a compliance visit a few months into 2013 which reviewed “several employee files and patient charts, specifically reviewing employee competency. It was noted at this time that our agency was in compliance, including the CPR and first-aid process that is now considered a non-compliance issue. The only instruction that was given from the above named surveyors was that the CPR and first-aid could not be solely internet based, in which none of ours were. Had any further instruction been given, we could have immediately changed our policy and procedures.”

“Our goal as an agency is always to provide excellent care to our community and to remain complaint with all ODM rules. At the survey end we were deemed competent to continue providing services according to current policy and procedure and ORC,” Smith stated. “There was no Notice of Operational Deficiency and no request for any Plan of Correction.”

Information provided by the Ohio Auditor’s Office.

Staff Report