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Series: Home Health Compliance with Medicare Requirements

Announced on  | Last Modified on  | Series Number: W-00-24-35712
Status
Active
Agency
Centers for Medicare and Medicaid Services

OBJECTIVE

The Medicare home health benefit covers intermittent skilled nursing care, physical therapy, speech-language pathology services, continued occupational services, medical social worker services, and home health aide services. For CY 2014, Medicare paid home health agencies (HHAs) about $18 billion for home health services. Centers for Medicare & Medicaid Services' Comprehensive Error Rate Testing (CERT) program determined that the 2014 improper payment error rate for home health claims was 51.4 percent, or about $9.4 billion. Recent OIG reports have similarly disclosed high error rates at individual HHAs. Improper payments identified in these OIG reports consisted primarily of beneficiaries who were not homebound or who did not require skilled services. We will review compliance with various aspects of the home health prospective payment system and include medical review of the documentation required in support of the claims paid by Medicare. We will determine whether home health claims were paid in accordance with Federal requirements.

There are 8 projects in this series.

Project titles will remain unpublished until projects are complete and reports are posted.

ACTIVE PROJECTS IN THIS SERIES (3)

Project A-02-22-01023 • Announced on Sep 12, 2022

Project A-05-24-00007 • Announced on Dec 18, 2023

Project A-05-24-00014 • Announced on Jul 22, 2024

COMPLETED PROJECTS IN THIS SERIES (5)

Medicare Home Health Agency Provider Compliance Audit: Guardian Home Care, LLC

Project A-07-24-05146 • Completed on December 15, 2025

Medicare Home Health Agency Provider Compliance Review: VNA Care Network

Project A-05-22-00016 • Completed on October 23, 2025

Home Health Compliance with Medicare Requirements - Audit 4

Project A-05-23-00002 • Completed on July 9, 2025

Home Health Compliance with Medicare Requirements - Audit 3

Project A-05-22-00017 • Completed on June 30, 2025

Home Health Compliance with Medicare Requirements - Audit 5

Project A-05-23-00017 • Completed on December 19, 2024

TIMELINE

  • April 4, 2022
    Series Number W-00-24-35712 Assigned
  • April 4, 2022
    Project Announced

    Medicare Home Health Agency Provider Compliance Review: VNA Care Network - A-05-22-00016

  • May 3, 2022
    Project Announced

    Home Health Compliance with Medicare Requirements - Audit 3 - A-05-22-00017

  • September 12, 2022
    Project Announced

    Project A-02-22-01023

  • October 4, 2022
    Project Announced

    Home Health Compliance with Medicare Requirements - Audit 4 - A-05-23-00002

  • June 29, 2023
    Project Announced

    Home Health Compliance with Medicare Requirements - Audit 5 - A-05-23-00017

  • December 18, 2023
    Project Announced

    Project A-05-24-00007

  • January 26, 2024
    Project Announced

    Medicare Home Health Agency Provider Compliance Audit: Guardian Home Care, LLC - A-07-24-05146

  • July 22, 2024
    Project Announced

    Project A-05-24-00014

  • December 19, 2024
    Project Complete - A-05-23-00017

    Home Health Compliance with Medicare Requirements - Audit 5 has been marked as complete. This audit resulted in 3 recommendations.

  • June 30, 2025
    Project Complete - A-05-22-00017

    Home Health Compliance with Medicare Requirements - Audit 3 has been marked as complete. This audit resulted in 3 recommendations.

  • July 9, 2025
    Project Complete - A-05-23-00002

    Home Health Compliance with Medicare Requirements - Audit 4 has been marked as complete. Report Published

  • October 23, 2025
    Project Complete - A-05-22-00016

    Medicare Home Health Agency Provider Compliance Review: VNA Care Network has been marked as complete. This audit resulted in 3 recommendations.

  • December 15, 2025
    Project Complete - A-07-24-05146

    Medicare Home Health Agency Provider Compliance Audit: Guardian Home Care, LLC has been marked as complete. Report Published

  • Today
    3 Projects In-Progress
  • Est FY2026
    Estimated Fiscal Year for Series Completion

5 REPORT PUBLISHED

Medicare Home Health Agency Provider Compliance Audit: VNA Care Network (A-05-22-00016)

VNA Care Network complied with Medicare billing requirements for 85 of the 100 home health claims we reviewed. For the remaining 15 claims, VNA Care Network incorrectly billed Medicare for claims with unsupported codes, services that did not meet plan of care requirements, invalid face-to-face encounters, skilled services that did not meet medical necessity requirements, and services that did not meet comprehensive assessment requirements.

VNA Care Network received overpayments totaling $6,171 for the claims in the sample.

26-A-05-005.01 to CMS - Open Unimplemented
Update expected on 04/22/2026
We recommend that VNA Care Network refund the $6,171 in overpayments to the Medicare program.

26-A-05-005.02 to CMS - Open Unimplemented
Update expected on 04/22/2026
We recommend that VNA Care Network consider conducting one or more internal audits or investigations for claims before and after our audit period based on the risks identified by this audit to identify any similar overpayments the provider might have received and return any identified overpayments to the Medicare program.

26-A-05-005.03 to CMS - Open Unimplemented
Update expected on 04/22/2026
We recommend that VNA Care Network strengthen its review processes for identification of inaccuracies in medical record documentation to improve compliance with Medicare billing requirements.

View in Recommendation Tracker

Medicare Home Health Agency Provider Compliance Audit: HRS Home Health (A-05-22-00017)

HRS Home Health complied with Medicare billing requirements for 80 of the 100 home health claims we reviewed. For the remaining 20 claims, HRS Home Health incorrectly billed Medicare for claims with unsupported codes and for skilled services that did not meet requirements, including plan of care requirements.

  • Fifteen claims did not meet billing and coding requirements, resulting in overpayments totaling $2,291.
  • Four claims did not meet plan of care requirements but did not result in an overpayment.
  • One claim did not meet skilled need requirements but did not result in an overpayment.

Based on our sample results, we estimate that HRS Home Health received overpayments of at least $100,696 for the audit period.

25-A-05-076.01 to CMS - Open Unimplemented
Update expected on 06/03/2026
We recommend that HRS Home Health refund the $100,696 in estimated overpayments to the Medicare program.

25-A-05-076.02 to CMS - Closed Implemented
Closed on 12/03/2025
We recommend that HRS Home Health consider conducting one or more internal audits or investigations for claims after our audit period based on the risks identified by this audit to identify any similar overpayments the provider might have received and return any identified overpayments to the Medicare program.

25-A-05-076.03 to CMS - Closed Implemented
Closed on 12/03/2025
We recommend that HRS Home Health strengthen its review of medical record documentation to ensure compliance with Medicare billing requirements.

View in Recommendation Tracker

Medicare Home Health Agency Provider Compliance Audit: Sunflower Home Health (A-05-23-00002)

Sunflower Home Health complied with Medicare billing requirements for all 100 of the home health claims that we reviewed.

No recommendations were issued as a part of this report.

Medicare Home Health Agency Provider Compliance Audit: Bridge Home Health (A-05-23-00017)

25-A-05-031.01 to CMS - Closed Implemented
Closed on 07/03/2025
We recommend that Bridge Home Health refund the $6,046 in overpayments to the Medicare program.

25-A-05-031.02 to CMS - Closed Implemented
Closed on 07/03/2025
We recommend that Bridge Home Health identify similar instances of noncompliance that occurred before, during, and after the audit period and determine the impact and return any overpayments to the Federal Government.

25-A-05-031.03 to CMS - Closed Implemented
Closed on 06/17/2025
We recommend that Bridge Home Health strengthen its review of medical record documentation to ensure compliance with Medicare billing requirements.

View in Recommendation Tracker

Medicare Home Health Agency Provider Compliance Audit: Guardian Home Care, LLC (A-07-24-05146)

Guardian Home Care complied with Medicare billing requirements for 97 of the 100 home health claims we reviewed. For the remaining three claims, Guardian Home Care incorrectly billed Medicare for claims with unsupported codes or for a skilled service that did not meet a plan of care requirement.

  • Two claims did not meet billing and coding requirements, resulting in overpayments totaling $123.
  • One claim did not meet a plan of care requirement, resulting in an overpayment of $1,567.

Guardian Home Care received overpayments totaling $1,690 for the claims in the sample.

No recommendations were issued as a part of this report.
Work Plan Type
Office of Audit Services
HHS Agencies
Centers for Medicare and Medicaid Services
Issue Areas
-
Target Groups
Elderly
Financial Groups
Medicare A