HHA Model Compliance Plan / Risk areas

Why This Topic Matters

Home health agencies operate in a heavily regulated environment where billing, documentation, referrals, patient coverage, and operational controls can create compliance exposure. Understanding the OIG’s risk categories helps organizations focus compliance efforts where problems are most likely to arise.

Article Sections

1. Compliance program approach and OIG oversight

   Introduces the role of written policies, employee participation, training, and the use of OIG materials in shaping a home health compliance program. It also references broader OIG oversight tools used to identify concern areas.

2. OIG-identified home health risk areas

   Presents the major categories of compliance risk identified for home health agencies. The section groups concerns involving billing, documentation, referrals, staffing, patient eligibility, oversight, and other operational practices.

3. Prior noncompliance and additional risk assessment

   Addresses how an agency’s history of noncompliance can signal additional areas needing policy review and preventive measures. It emphasizes ongoing assessment and incorporation of new risks into the compliance program.