Hospice and Home Health Agency External Audit Defense

Hospices and home health agencies are constant targets in investigations against Medicare fraud. As a result, home health/hospice providers are under constant fear of audits and investigations. Providers that fail to adhere to financial reporting laws and related regulations face serious consequences ranging from hefty penalties to federal imprisonment.

Our work is to defend home health agency and hospice owners from external audit results capable of resulting in legal and/or financial problems. Corporate Investigation Consulting supports its clients throughout, including times of crisis.

We can respond to external audit results that raise issues on business transactions, regulatory issues, compliance issues, and litigation.

Put our highly experienced team on your side

Roger Bach
Roger Bach

Former Special Agent
(DOJ-OIG & DEA)

Timothy E. Allen
Timothy E. Allen

Former Senior Special Agent
(U.S. Secret Service & DOJ-OIG)

Chris Quick
Chris Quick

Former Special Agent
(FBI & IRS-CI)

Maura Kelley
Maura Kelley

Former Special Agent
(FBI)

Ray Yuen
Ray Yuen

Former Supervisory Special Agent
(FBI)

Michael Koslow
Michael Koslow

Former Supervisory Special Agent
(DOD-OIG)

Marquis D. Pickett
Marquis D. Pickett

Special Agent
U.S. Secret Service (ret.)

Dennis A. Wichern
Dennis A. Wichern

Former Special Agent-in-Charge
(DEA)

External Audit Concerns

External audit defense services are crucial given the complexity of healthcare laws nationwide governing hospices, home health agencies, federal agencies, and audit contractors. Agencies like the FBI, DEA, OIG, and CMS can take action on any business. However, these agencies have more incentives to target businesses operating in the healthcare industry.

While such agencies need intent to carry out external audits or other investigations, many honest mistakes done by hospices and home health agencies can resemble fraudulent billing, among other external audit issues. Such mistakes can result in civil charges that attract financial liability and/or exclusion from federal benefit programs.

Corporate Investigation Consulting exists to defend hospices and home health agencies that are unfairly targeted or subjected to unfavorable actions like lawsuits, hefty fines, and exclusion.

Reasons Why Hospice or Home Health Providers are Targeted

Honest mistakes aside, home health agencies and hospices are targeted by investigators or auditors mainly for financial reasons. Audit contractors have a financial incentive to be aggressive on as many hospices/home health agencies as possible.

Federal agencies also have a financial incentive to deal with Medicare fraud common in hospices and home health agencies to save on funding for national health programs. The increased interest is therefore understandable. Other reasons for targeting hospices and home health agencies include; lawsuits originating from disgruntled former employees or competitors in qui tam lawsuits with the DOJ or OIG.

A provider can also be flagged automatically by data analytics tools showing signs fraudulent activity. A RAC (Recovery Audit Contractor) or Medicare Audit Contractor (MAC) may also subject any hospice or home health provider to an audit.

We can investigate the circumstances leading to an external audit and provide appropriate external audit defense.

External Audit Defenses

We have legal experts, former special agents, former intelligence officers, and many other critical experts nationwide capable of defending home health agency and hospice owners from unfavorable external audit results.

Business transaction defense: We can defend providers against external audits done by regulators and other entities that result in business transaction issues. We can handle employment agreement issues, independent contractor issues, purchase/sale agreement issues, and many other compliance issues on business structure and home health agency and hospice formation.

Our experts understand business transaction compliance to the letter and are capable of challenging how external audits are done and how evidence is collected.

Regulatory defense: Corporate Investigation Consulting can also defend home health agencies, and hospices found to have regulatory issues. We can assist with DPH (Department of Public Health) licensing investigations and appeals, reimbursement audits from Medicare, CMS, and other private & government payers.

We can also assist investigations initiated after external audits by the OIG, Safeguard Services, FBI, DOJ, DHCS, etc. We study fraud and abuse cases to the letter to ensure they are investigated according to the law and procedure.

Compliance defense: Our audit experts also handle licensing, reimbursement, and operational compliance issues. We can also represent clients in other compliance issues such as Medicare enrollment, corrective action plans, among other compliance issues like audit risk assessment issues, and local coverage compliance and documentation issues. We’ve defended many home health agencies and hospices in the U.S. with inpatient claims, special physicians service claims, and terminal status claims. Other compliance issues we can defend include hospice cap compliance and HIPPA & state patient data privacy & security claims.

Litigation defense: We also handle licensure defense & appeals, overpayment appeals, payer & reimbursement disputes, Medicare provider enrollment appeals, business & employment litigation, overpayment appeals, and exclusions/suspensions by government entities like the OIG, and CMS.

Our external audit experts understand procedures and laws governing audits nationwide. We can assess audit processes and evidence of non-compliance or wrongdoing and tell if such audits abide by the law. Many hospice and home health owners who have come to us have had their external audit concerns addressed.

Contact us now at 866-352-9324 or reach out online if you face federal imprisonment, hefty fines, or other unfavorable consequences because of external audit results. External audit issues should be handled by experts with firsthand experience in dealing with auditors and investigations.

Common Healthcare Violations Committed by Home Health/Hospice Care Providers

We can defend you against common violations that focus on valid certification. Medicare billing is also a common problem. Medicare billing rules require patients to gain hospice care eligibility only when a physician certifies that the patient has 6 or fewer months to live. Patients gain eligibility for home health reimbursement via Medicare only if they are certified homebound.

Most hospices and home health providers fail to get certifications, falsify certifications, or rely on fraudulent certification. Other common problems include failure to discharge patients who have improved. Such violations can attract criminal or civil charges.

Certification aside, other healthcare violations to look out for include failure to get valid/signed election statements (from patients) before commencing care. Some providers also order medication for treating other patient conditions that aren’t covered when medication is supposed to manage pain. Some providers also order unnecessary equipment like wheelchairs, walkers, beds, etc.

Other notable violations include medical billing violations such as billing for services/medication that isn’t provided, double billing and preparing inaccurate cost reports. Since hospice and home health agency owners are culpable for such violations, even though they may be committed by staff, we are always ready to help.

Get a free-external audit defense consultation now to understand how we help hospice, and home health agency owners defend themselves from common healthcare law violations in the U.S.

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