Evidence record

Hospice Care Claims and Fiscal Agent Contract

Jurisdiction
Nevada
Publication date
September 10, 2024
Source record
Original document linked
Open original reportOriginal source available

Findings

7

Recommendations

10

Overall conclusion

The Division lacks adequate controls to ensure hospice care provider payments comply with federal and state Medicaid policies.

Scope

Audit covered calendar years 2020-2022 and prior years, examining MMIS hospice care claims, service-rate billing, death-date processing, and fiscal agent contracting practices as administered by the Division of Health Care Financing and Policy.

Findings (7)

Each finding has a stable link.

  1. F-893

    Hospice Providers Improperly Paid for Duplicate Room and Board Services: identification of 115 duplicate dates of service (2% of 5,509 claims) with estimated overpayments exceeding $155,000 during calendar years 2020-2022 due to MMIS controls gaps.

  2. F-894

    Improper Use of the Higher Routine Home Care Rate: conservatively estimated overpayments of about $114,000 for 2020-2022 due to billing the higher routine home care rate beyond the initial 60 days.

  3. F-895

    Service Intensity Add-On (SIA) Rate Used Inappropriately: improper payments estimated at about $117,000 for 2020-2022; issues include use before the last 7 days of life, dates of death, and daily hour limits being exceeded.

  4. F-897

    Fiscal Agent Contracting Process Can Be Improved: frequent contract amendments since 2011 increasing the maximum to $803 million (from $176 million) without competitive bids; multiple amendments and lack of formal RFP process.

  5. F-892

    The Division lacks adequate controls to ensure hospice care provider payments comply with federal and state Medicaid policies, leading to improper payments.

  6. F-896

    Inadequate Controls Allowed Service Payments for Deceased Recipients: four dates of service in 2020-2022 claimed after death, with immaterial amounts but potential significance across all claims.

  7. F-898

    MMIS System Modernization and Controls Gaps: older system controls not fully carried over to MMIS modernization, contributing to improper payments.

Recommendations (10)

  1. R-793

    Analyze hospice provider claims to identify those providers that received overpayments for duplicate hospice room and board services and recoup the overpayments.

    Related finding F-893
  2. R-794

    Create MMIS system controls to prevent providers from receiving payment for the higher hospice routine home care rate if the recipient is continuously enrolled in hospice care for over 60 days.

    Related finding F-894
  3. R-795

    Analyze hospice provider claims to identify those providers that received overpayments for the higher hospice routine home care rate and recoup the overpayments.

    Related finding F-894
  4. R-796

    Create MMIS system controls to prevent improper payment of the service intensity add-on rate.

    Related finding F-895
  5. R-797

    Modify the Medicaid Service Manual for hospice services to include the proper use of the service intensity add-on rate.

    Related finding F-895
  6. R-798

    Modify the MMIS system controls to limit the service intensity add-on amount paid to only 4 hours per day.

    Related finding F-895
  7. R-799

    Develop a process to identify improper payments for services claimed to be rendered after a recipient’s date of death and recoup any improper payments identified.

    Related finding F-896
  8. R-800

    Work with the Department of Administration, Purchasing Division to identify, document, and update specifications so an effective RFP can be prepared before the expiration of the current contract in June 2028.

    Related finding F-897
  9. R-801

    Competitively solicit bids for a fiscal agent before the current contract term ends, in compliance with state policies.

    Related finding F-897
  10. R-792

    Create MMIS system controls to prevent hospice providers from receiving payment for duplicate hospice room and board services.

    Related finding F-893