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OIG Is Auditing Home Health Admission Source Codes 61 and 62

Adult daughter helping her elderly mother get out of a hospital bed before discharge

Home health admission source is now on an active federal audit list. The HHS Office of Inspector General has a nationwide audit underway, OAS-26-05-056, announced April 23, that looks at home health claims billed with occurrence codes 61 and 62. Agencies use those codes to show the patient had an institutional stay in the 14 days before the home health period started. Home Health Brief walked through the audit on Oct. 19, next to a June OIG hospice report where 45 of 100 sampled certification periods didn't meet Medicare requirements.

Why does a single code draw this much attention? Under PDGM, admission source is one of five variables Medicare uses to place each 30-day period into one of 432 case-mix groups. An institutional admission pays more than a community admission. OIG says earlier audits found agencies coding institutional admissions based on emergency room visits or observation stays, and neither one counts as an inpatient stay. OIG also notes agencies sometimes report these codes when no matching Medicare inpatient claim exists.

Where home health admission source coding goes wrong

Most of these errors start at intake, long before billing sees the claim. A referral says the patient was "discharged from the hospital," and nobody asks whether the patient was admitted or kept under observation. Those two situations look the same to a family and to a busy referral coordinator. They don't look the same to Medicare. A few checks fix most of it. Ask the referring facility for the discharge summary and confirm inpatient status in writing. Record the discharge date and count the 14 days yourself. If the patient only had an ER visit or an observation stay, code the period as a community admission. And keep the proof in the chart, so a reviewer finds it without a phone call.

The audit has no published findings yet, which gives you time to clean things up before results arrive. Pull a sample of recent periods billed with 61 or 62 and see whether each one has a documented inpatient or post-acute stay behind it. If a handful don't, you've found a training gap at intake, not a billing problem. CareSync® was built around giving office teams a clear view of what happened on each visit, and we hear the same complaint from agencies over and over. The facts behind a claim live in too many places. Whatever system you use, put the discharge summary next to the start-of-care record and your next review gets a lot shorter.

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