As the Centers for Medicare & Medicaid Services (CMS) and Department of Justice (DOJ) intensify anti-fraud enforcement in the home health industry, established providers are focusing on reinforcing quality, documentation integrity, proactive oversight and other compliance models already in place, leaders told Home Health Care News.

“Our strategy is really about making sure people understand what we do in the community, why it’s important and ensuring that people get access to high-quality, highly reliable healthcare in the community and the home,” Christopher Rinn, president and CEO of VNA Health Group, told HHCN.  

In March, a letter signed by the National Alliance for Care at Home, LeadingAge, LeadingAge California and the California Association for Health Services at Home stated that sweeping program integrity actions could cause physicians and practitioners to become more cautious about making home health and hospice referrals.

While some providers have said that CMS’ expansive moratorium on Medicare home health enrollment will not affect their plans for expansion, other providers and advocacy groups have decried the moratorium, saying that it threatens providers’ ability to expand and will reduce access to care.

The hospice industry has an extensive history of fraud hotspots and anti-fraud measures, implicating some legitimate providers and prompting others to update their public relations strategies.

However, Rinn said VNA Health Group has not felt the need to combat potential negative perceptions of home health in its external communications strategy. VNA Health Group’s established compliance structure and regulatory adherence, including external audits and monitoring, audit committees and enterprise-wide compliance training, meant the company did not need to change its internal responses to the crackdown either, Rinn explained. 

“There’s been no fundamental change in how we’ve approached public relations [or] marketing,” Christopher Rinn, CEO of VNA Health Group, told HHCN. “The federal focus on fraud, waste and abuse quite frankly, doesn’t impact us. [It] doesn’t impact our marketing or PR approach.”

Founded in 1912, Neptune, New Jersey-based VNA Health Group provides home health services within New Jersey.

Signaling quality

Empath Health also has not had to change its public relations strategies amid the anti-fraud crackdown in the home health industry, Laura Mosby, chief ethics and compliance officer at Empath Health, told HHCN in an email.

“While regulatory developments are always important to monitor, our communications are not driven by individual enforcement trends,” Mosby said. “Instead, we focus on consistently sharing how we serve patients and families with compassion, clinical excellence and integrity across all our programs.”

Clearwater, Florida-based non-profit Empath Health provides home-based care services including home health, as well as hospice, personalized therapies and other healthcare offerings across numerous locations in Florida. In April, Empath Health completed its two-year integration of hospice provider Trustbridge.

Hospice has long garnered regulatory scrutiny for fraud. However, Mosby noted that navigating hospice fraud crackdowns has not necessarily informed how the company maneuvers more recent enforcement actions within home health.

“Whether in hospice, home health or other services, we believe stakeholders value organizations that communicate openly about their standards, processes and commitment to doing the right thing,” Mosby said. “Our approach is guided by those principles regardless of care setting.”

While neither VNA Health Group nor Empath Health have had to alter its external communications strategies, misconduct from other providers affects legitimate ones, especially when fraudulent reporting influences quality comparisons and policy decisions.

“Not being truthful in their documentation and their quality scores and their satisfaction scores and their outcomes, that’s going to skew the data negatively, and good actors are going to be impacted,” Rinn said. “This administration has heard those calls and those concerns, and they’re taking action — and I applaud that, quite frankly.”

Third-party accreditation also helps home-based care providers signal quality. For instance, Empath Personal Care publicly displays its accreditation from the Accreditation Commission for Health Care. ACHC is an accreditation organization for providers of home-based care services such as home health, hospice and in-home hospital care, as well as residential and outpatient care. 

“We educate providers on the intent and requirements of our standards and validate their compliance through onsite review,” Susan Mills, ACHC senior program director overseeing home health, hospice and home infusion therapy accreditation, told HHCN in an email. “In that role, we do confirm that the agency’s marketing materials use clear language and accurately describe the care and services offered.”

Accreditation is just one way for home-based care providers to indicate compliance and merit to patients, payers and referral partners, Mills added. Agencies must continue reinforcing their value to the broader public.

“We don’t say ‘This is how you build trust,’ but at the core, meeting the standards represents proof of trustworthiness,” Mills added. “Then it’s up to the individual agency to communicate that achievement and connect the dots for the constituents they serve.”