These are not fun terms to explore, but with RAC auditors on the hunt nationwide, it’s an unavoidable truth for the home healthcare industry.
Let’s begin by exploring what these terms mean - basically, they mean closing down your practice in a responsible manner. Recently, we’ve seen a wave of closures related to Medicare Fraud investigations from the Office of Inspector General and the Medicare Fraud Division of the FBI, but the closures aren't always that sensational. With the thin margins most house call practices operate on, it could be a simple matter of running out of operating capital.
Whether it’s criminal, financial, or otherwise, the stakes are the same: the health of your patients and the livelihood of your providers are on the line if the process is done incorrectly. Nine times out of ten, most of our clients don’t have a divestment document on hand in the event of a worst-case scenario. But don’t take my word for it; let’s walk through a few basic questions:
1) In the event of a shutdown, what management is notified first – and whose responsibility is it to inform the rest of the staff? How is that process structured?
2) Are there safeguards in place to protect HIPAA information, as well as office property? A company closure will be a time of great uncertainty and anxiety for your management and staff. In our experience, this can lead to a "mob mentality" where your employees aren't acting like their best selves. Office furniture, computers, and even patient lists can walk out the door if the process isn’t structured correctly.
3) Who is responsible for contacting the medical board to inform them of the development and recruit their help so your providers (and your practice) are not accused of patient abandonment?
4) Who is responsible for informing the patients? Filling 30-day refills upon discharge? What happens if that person does not show up for work?
This is just a small sample of the complicated logistics issues that go into a divestment plan. I’ll admit that it’s a bit of a grim process, but one that faces up to the realities of our industry. In the last two years, we have all seen a notable increase in the volume of audits on not only house call practices, but also for our home health agency and DME partners, as well.
Hopefully you will never need it ... but having a good divestment plan in place will not only limit potential legal fallout, it will also ensure great continuity of care for your patients.