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08/08/2016

Ohio Medicaid to Audit ALL Hospices' Election Statements

Ohio Medicaid to Audit ALL Hospices' Election Statements

In 2014, the OIG performed two audits in Ohio; one looked primarily at Medicaid rules, requirements, and licensure criteria to ensure that hospice care is furnished by qualified workers.  The second audit (May 2014, A-05-12-00087) was to determine whether Ohio Medicaid correctly reimbursed hospices for claims submitted by hospices in Ohio.

In the examination of 100 sampled claims, OIG found that the Ohio Department of Medicaid paid 16 claims that had supposedly not properly followed Federal Medicaid requirements related to Medicaid beneficiaries electing the hospice benefit.

To address this issue, ODM will audit Medicaid election statements from all Ohio Hospices serving Medicaid patients beginning late August. In discussions with ODM, they expect this audit to take place through October 31, 2016. ODM will send a notification to each hospice requesting a copy of their election statement form. It's likely that the ODM request will be sent to the contact listed on the 855A. As soon as the request goes out from ODM, LeadingAge Ohio will notify members again.

The Department will then audit the form, comparing it to the requirements listed in the related hospice electronic manual, Chapter 9, and the Ohio Medicaid Hospice Rules. The Department is expecting 100% participation. ODM said it is acceptable to have a combined Medicare/Medicaid Statement of Election as long as all the necessary criteria are on the statement and the statement can clearly delineate (by a circle or mark) which benefit is being elected; Medicare, Medicaid or both.

ODM will also be reporting to the OIG the results of compliance to the issues identified in the audit on a semi-annual basis. They filed a report with the OIG in March of 2016 and will file another report in December 2016 or early 2017. Moving forward, they will submit a report every six months. In the forthcoming semi-annual reports, ODM will audit 70 election statements with each six-month report. 

What Hospices Need to Do

Compare the requirements to your election statement to determine if your statements have all the necessary components included on the statement. The language in RED in the two document links below identifies required items to meet the criteria for the Medicaid election statement.

Below is information from the Hospice Medicare Manual, Chapter 9, as well as the Ohio Department of Health rule 5160-56-02, regarding Hospice Election and what details are supposed to be listed on the form. Hospice programs have developed their election statements differently, sometimes combining both Medicare and Medicaid election form criteria on one form while others have two different forms. Chapter 9, from the Hospice Medicare Manual, is interpreted to identify language needed on the election statements addressing both Medicare and Medicaid beneficiaries.  Providers should recognize that if a patient is dual eligible, they need to elect both Medicare and Medicaid hospice benefit.

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