Often when we think of the word predator our mind goes to molesters. This blog does not address issues involving molesters. Our focus is the development and success of adult day care providers. Hence we are talking about those predators who look for ways to defraud Medicare and other payers and who see adult day care participants as easy prey. For the adult day care program that doubles as a Medicare certified CORF or other outpatient rehabilitation program you likely are less at risk but for those who have arrangements with Medicare certified home health agencies your exposure can be great.
Some of these predators even try to get you to hire someone they can control which allows them access to your participant information. They often form or pretend to be a personnel pool, offering you a medically trained receptionist, etc. for an incredibly affordable wage. Great deal, right? Others seek to bribe your own clerical or transportation staff. They may not be strangers as in some cases they are already providing nursing, physical therapy, occupational therapy or speech therapy to those enrolled in your program.
What they really want are all of the Medicare and social security numbers of everyone enrolled in order that they might bill for skilled services, even though they are not providing them for everyone in your program. Maybe you have a daily attendance of 80 but they are currently seeing 10. The real problem with this from a legal perspective is that you could be on the hook criminally speaking for this fraud just as the actual perpetrators are. A claim of ignorance may not be your salvation!
So remember these tips:
- Ask care providers to obtain what they need for billing from the referring physician who arranged for their services.
- Guard the dates of birth, Medicare numbers, etc. of all program participants, allowing access to key managerial employees only. Keep assessments, plans of care, etc. in a separate binder away from other more highly personal biographical data.
- Designate one person who can provide participant data to a provider of care services or medical equipment and that person only. Such limited access should be written into an actual center policy and strictly enforced.
Obviously we want to focus on the truly important things including daily, person-centered care. However, these administrative precautions can sink you quickly so let’s plan in advance not to be a victim.
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