LHC Group has developed extensive auditing and monitoring programs for our home health, hospice and LTACH Divisions to assess internal controls and processes for compliance with all applicable laws, rules and regulations. The Office of Inspector General has published areas of concern for home health agencies, hospice and acute care facilities. Our Compliance Department has developed individual work plans and audit tools for each area of concern to assist in evaluating our Company’s risk for each of these areas. The Compliance Department staff works in conjunction with other departments to accomplish the necessary goals and objectives for each compliance work plan.

An example of certain audits that are conducted on and off-site include:

• OIG and Risk-Based Work Plan Audits that encompass guidelines surrounding Stark and Anti-kickback regulations, Service Utilization, Part B payments, HIPAA compliance, Accuracy of Billing and Coding, Discharge and Admission procedures and other important risk areas.
• Provider-level clinical and billing compliance audits of medical records performed by clinicians and certified home health coders.
• Monthly review and follow-up audit of all billing compliance indicator findings from the Performance Improvement and Quality monitoring activities.
• Monthly customized compliance risk indicator reports for every home health agency to track and monitor key risk indicators such as therapy utilization, outliers and length of stay, to name a few.
• Monthly audit of sales and marketing expenses and compliance with our Code of Conduct for Sales and Marketing.
• Routine audits of our Joint Ventures.
• Monthly audits of our Medical Director program including a review of all Medical Director timesheets.

Audit frequencies range from monthly to annually depending on potential risk and vulnerability factors. Findings and recommendations are documented and monitored through our compliance information system. Each review provides Company leadership with valuable guidance to assist in strengthening controls and improving overall performance throughout our agencies and facilities. The analysis of this data assists in identifying both trends and opportunities for improvement within our company.

Annual Risk Assessment

Our Compliance Department conducts an annual risk assessment. This annual risk assessment process includes (1) review of the OIG Work Plan and other regulatory and industry guidance for risk areas applicable to each industry in which we operate, (2) interviews, including field clinicians, agency/facility leadership, home office and senior management, (3) conducting surveys to gather additional feedback and (4) processing all qualitative and quantitative information to determine appropriate risk areas and future audit activity for the approaching year’s audit work plan.