A review of Medicare home health services by the Department of Health and Human Services' Office of Inspector General has found that 32 percent of claims did not document the required face-to-face encounters, resulting in $2 billion in payments that should not have been made. In addition, OIG concludes that oversight of the face-to-face requirement by the Centers for Medicare and Medicaid Services is minimal.

"CMS does not have a specific program to oversee compliance with the requirement for face-to-face documentation," states the OIG report. "Instead, it reviews the documentation when it conducts a medical record review as part of its general effort to deter and detect home health fraud."

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