OIG audit finds billing errors at Harris County home health care provider

The OIG released audit results for Home and Community Support Services Agency (HCSSA) provider Girling Community Care’s Bellaire operation.

The audit found that Girling complied with most HCSSA requirements, including developing individual service plans, attendant orientations, and supervisor visits for clients. However, Girling has opportunities to improve some of its processes. Specifically, the provider did not:

• Comply with certain electronic visit verification (EVV) visit maintenance requirements, leading to more than $15,000 in possible overbilling.
• Always perform timely attendant background checks.
• Consistently retain support to demonstrate that field supervisors met qualification requirements.

The audit explained that visit maintenance for the EVV occurs when the device does not automatically capture required data elements, which can occur due to a shift in scheduled service times. To maintain proper records, designated staff for the provider can edit data elements to reflect service delivery and avoid billing errors. Of the 14,912 transactions reviewed, 12,136 were missing required information and documentation. Many of these visits were able to be verified through other documentation methods. In total, 263 transactions were missing clock in and out times with no supporting documentation, leading to $15,353 in overpayment for services not provided. Auditors recommended that Girling should: 

• Strengthen controls over the visit maintenance process to ensure transactions missing service delivery times include the required data elements in the free text field.
• Repay the state of Texas a total of $15,353 for EVV transactions that did not contain the required information to verify the delivery of personal care services.

The audit also discovered safety concerns involving background checks for staff. For example, three of the 40 attendants receiving a criminal background check had their first face-to-face meeting with the client before the provider completed the review. Additionally, of the eight supervisors, one’s personnel record did not have sufficient evidence of mandatory education and experience to meet the requirements for the position. As a result, auditors recommended that the provider complete all required background checks and verify educational records before patient care begins.

The provider agreed to all recommendations, including the return of more than $15,000 to the state of Texas. 

For the full audit, visit the OIG website.