OIG Regulations for House Calls Bring Challenges for Doctors

Gregory A. Hood, MD

Disclosures

April 10, 2017

House Calls Provide Unforeseen Benefits

House calls have been an important, though intermittent, part of my career. They often provide information and an understanding that are not only necessary, given the patient's circumstances, but also impossible to find out readily through an office visit. Home visits are a vital need, but they have also become a special point of concern by the Office of Inspector General (OIG) for 2017. In fact, the OIG 2017 Work Plan established a priority for audit of home visit claims.

Reimbursement updates in 1998 led to an increase in home visits from 1.4 million in 1999 to 2.3 million in 2009, a trend that has continued annually since 2009. Both the frequency of these services and the growth of dedicated companies who provide this service by physicians, and in the name of physicians with nonphysician providers, have led the OIG to question whether all of the visits are "medically necessary." This is, of course, a requirement for all covered services. Most importantly, the visits cannot be for the convenience of the patient, the patient's family, or the physician (or provider).

Indeed, home visits are more convenient for the patient, but the benefits of the visit for the patient are not always apparent until you get to the home, as I realized when I made a house call to an elderly woman when I was a member of a very large West coast medical group. Although the patient was well-maintained on her medications, she began to suffer from an inexplicably persistent exacerbation of her emphysema. In spite of a number of office visits and thorough history-taking, she continued to suffer, so I made arrangements for the house call.

When I arrived at her home, I was greeted by a kitten. The patient never mentioned that she had a cat, even though we questioned her at the office on more than one occasion. That day I learned how valuable home visits are compared with relying on a patient to bring up pertinent information when they are in the office.

I have known physicians who have made house calls for the last 20 years, even as the OIG raises legitimate questions as to the true necessity of such visits and requires these providers to show that the visit is necessary.

What Are the Patient's Needs?

Is the home visit based upon a one-time need, or is the visit in response to an ongoing or permanent need because of the patient's physical, medical, mental, or psychological issues? Answers to these questions should be documented. It is unacceptable to justify home visits based on personal preferences or financial conveniences. Having a regular, set schedule for visits as a matter of routine or convenience for the provider will not pass muster.

Specific requests by patients or medically appropriate judgments and standards of care in treatment protocols/monitoring should be understood as much more likely to pass an audit.

Patients who are not physically capable of traveling to the office, such as one of my patients who has a recurring unstable pattern of health and another patient who needs periodic blood pressure monitoring and examinations to maintain the standards of care on his cardiovascular and cerebrovascular protections, will more likely pass an audit.

Home visits are acceptable for patients who can physically come to the office but who experience significant agitation or psychological difficulties, such as a patient who pushes a staff member.

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