Medicare Home Health Agency Provider Compliance Audit: VNS Health
Summary
HHS OIG completed a compliance audit of VNS Health's Medicare home health claims for the period July 1, 2020, through June 30, 2022. Of 100 sampled claims, 16 contained errors resulting in $2,965,484 in overpayments. OIG recommends VNS Health refund the overpayments and conduct internal audits to identify similar billing errors.
What changed
HHS OIG audited 100 sampled home health claims from VNS Health spanning July 2020 through June 2022. The audit identified 16 claims with errors: 12 claims failed billing/coding requirements, 4 claims failed face-to-face encounter requirements, and 2 claims failed plan of care requirements (totaling more than 16 due to some claims having multiple errors). Based on the sample, OIG estimates total overpayments of $2,965,484 from $191.9 million in Medicare payments reviewed.\n\nVNS Health must refund $2,965,484 to Medicare and should conduct internal audits of claims after the audit period to identify additional overpayments. The provider should strengthen medical record documentation review processes. VNS Health did not concur with OIG's recommendations but agreed to repay $12,606 for five claims with actual identified errors. Healthcare providers offering home health services should review their billing practices for compliance with Medicare requirements, particularly face-to-face encounter documentation and plan of care certifications.
What to do next
- Refund the $2,965,484 in identified overpayments to the Medicare program
- Conduct internal audits of post-audit period claims to identify similar overpayments and return any additional funds identified
- Strengthen medical record documentation review processes to ensure compliance with Medicare billing requirements for face-to-face encounters, plan of care certifications, and billing/coding
Source document (simplified)
Medicare Home Health Agency Provider Compliance Audit: VNS Health
Issued on
03/26/2026
| Posted on
03/30/2026
| Report number: A-02-22-01023
Report Materials
Why OIG Did This Audit
- In calendar year 2023, Medicare paid home health agencies (HHAs) about $16 billion for home health services provided to about 2.8 million people enrolled in traditional Medicare. In that year, nearly 10,000 HHAs participated in Medicare.
- CMS determined through its Comprehensive Error Rate Testing program that the 2023 improper payment error rate for home health claims was 7.7 percent, or about $1.2 billion.
- This audit report, part of a nationwide series of home health audits, examined whether VNS Health complied with Medicare billing requirements.
What OIG Found
For the audit period (July 1, 2020, through June 30, 2022), VNS Health complied with Medicare billing requirements for 84 of the 100 sampled home health claims we reviewed. For the remaining 16 claims, VNS Health incorrectly billed Medicare. Specifically:
- Twelve claims did not meet billing and coding requirements.
- Four claims did not meet face-to-face encounter requirements.
- Two claims did not meet plan of care requirements. The total exceeds 16 because 2 claims contained more than 1 error.
Based on our sample results, we estimate that, of the $191,954,445 in Medicare payments covered by our audit, VNS Health received overpayments of at least $2,965,484 for the audit period.
What OIG Recommends
We made three recommendations to VNS Health, including that it (1) refund the $2,965,484 in overpayments to the Medicare program, (2) consider conducting one or more internal audits or investigations for claims after our audit period based on the risks identified by this audit to identify any similar overpayments the provider might have received and return any identified overpayments to the Medicare program, and (3) strengthen its review of medical record documentation to ensure compliance with Medicare billing requirements.
VNS Health did not concur with any of our recommendations, but it agreed to repay a portion of $12,606 in actual overpayments associated with five claims that resulted in errors.
Report Type Audit HHS Agencies Centers for Medicare and Medicaid Services Issue Areas – Target Groups Elderly Financial Groups Medicare A
Notice
This report may be subject to section 5274 of the National Defense Authorization Act Fiscal Year 2023, 117 Pub. L. 263.
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