OIG Is Medically Reviewing Home Health Documentation Right Now

There is an open item on the HHS Office of Inspector General work plan called Home Health Compliance with Medicare Requirements, report series W-00-24-35712. It was announced in April 2022, it is still active, eight audits in the series have already been completed, and OIG lists expected completion of the series in FY2026.

The phrase that matters in the work plan entry is this one: the audits “include medical review of the documentation required in support of the claims paid by Medicare.” Not a data-mining exercise. Not a statistical outlier screen. People reading records.

Why this series exists

OIG’s own justification points at the CMS Comprehensive Error Rate Testing program. For 2014, CERT put the home health improper payment rate at 51.4%, roughly $9.4 billion of about $18 billion in Medicare home health spending that year. That number is why home health has had a standing place in the work plan for more than a decade.

The picture has improved substantially since. In the FY2025 Medicare fee-for-service supplemental improper payment data, the overall Medicare FFS improper payment rate is 6.55% after adjustment for A/B rebilling, and home health agencies account for about $1.1 billion in projected improper payments. Of that, roughly $0.5 billion is attributed to insufficient documentation.

Read those two facts together and the shape of the problem changes. The volume came down. The character of the remaining errors did not. Close to half of what is still being called improper in home health is not fraud and not medically inappropriate care. It is care that happened and could not be evidenced. We went deeper on that distinction in insufficient documentation is the single largest home health payment error.

What the completed audits keep finding

The error categories OIG names across this series are consistent and unglamorous:

Billing and coding that does not match the record
Face-to-face encounter requirements not adequately met or documented
Skilled services billed without documentation supporting that the service was skilled

None of those are clinical judgment calls. All three are evidentiary.

The face-to-face requirement, precisely

Under 42 CFR 424.22, a face-to-face encounter must have “occurred no more than 90 days prior to the home health start of care date or within 30 days of the start of the home health care,” and the certifying practitioner “must also document the date of the encounter as part of the certification.” The encounter has to relate to the primary reason the patient needs home health.

Agencies rarely fail this because the encounter did not happen. They fail it because the date was never captured, or because the documentation in hand does not connect the encounter to the reason for the referral.

Where your own records stop counting — and this part is genuinely constrained

This is the piece most agencies get wrong, and it is worth stating exactly rather than approximately.

42 CFR 424.22(c) says documentation in the certifying practitioner’s medical record, or the acute or post-acute facility’s records, or both, “must be used as the basis for certification.” Agency-generated documentation may also be used to support eligibility, but only if it “can be corroborated by other medical record entries” in those records — “thereby creating a clinically consistent picture” — and only if the certifying practitioner “signs and dates the HHA documentation demonstrating that the documentation from the HHA was considered when certifying patient eligibility.”

So the honest answer to “will our intake notes save us?” is: not on their own. They are corroborating material that requires a signature and a consistent clinical picture elsewhere. An agency that treats its own call logs as primary eligibility evidence has misread the rule.

What agency records are good for is different and still valuable: establishing that a conversation occurred, when it occurred, what was ordered, what was promised, and who was told what. That is the material that closes the gap between a certification packet and a coherent story.

This post is general information about federal requirements, not legal advice. Medicaid home health programs and Medicare Advantage plans impose their own documentation and audit standards that vary by state and by contract; nothing here substitutes for reviewing your own payer agreements with counsel.

Nothing here requires you to record calls

Be clear-eyed about this, because vendors are not always. Neither the OIG work plan item, nor 424.22, nor the home health Conditions of Participation require call recording. What they require is documentation adequate to support the claim. Recording is one way to generate that documentation. A disciplined note-taking standard is another.

The question worth asking is not “are we required to?” but “when an auditor asks what was discussed on the referral call, can we answer?” For most agencies the honest response is a disposition code and a two-line note. We covered what that gap looks like in practice in what surveyors actually ask for.

Do this week

Pick a small, finite exercise rather than a documentation overhaul. Three hours of work will tell you where you stand.

Pull ten paid episodes at random from the last quarter. Not your cleanest ten. Random.
For each one, locate the face-to-face encounter date as documented in the certification, and confirm it falls in the 90-days-prior or 30-days-after window relative to start of care. Note how long each lookup took you. If it took more than five minutes, an auditor request for fifty episodes is a multi-week project.
For each one, find the evidence that the encounter related to the primary reason for home health. This is where episodes fail. A signed form with a date and no clinical linkage is thin.
Check whether any agency-generated documentation in the file is signed and dated by the certifying practitioner. If it is not, under 424.22(c) it is not doing the work you think it is doing.
Identify the conversation behind each gap. Where the record is thin, there was almost always a phone call — to the physician office, to the discharge planner, to the family — that contains the missing fact. Ask yourself whether that call is retrievable at all.

Audit request	What most agencies produce	What actually answers it
Date of face-to-face encounter	Certification form	Certification form plus the practitioner record it came from
Encounter related to primary reason for care	Diagnosis code	Clinical narrative linking encounter to the home health need
Basis for skilled need	Visit notes	Visit notes plus assessment showing why the service required a skilled clinician
What the referring physician ordered	Disposition code, “spoke with MD office”	A record of the actual conversation, with the order stated
Why care started when it did	Start-of-care date	Referral call, staffing attempts, and the order confirming the date

The window is the point

An audit series with an FY2026 expected completion date does not mean the audits stop. It means the reports land. Agencies read them, consultants build checklists around them, and MACs and UPICs tune their own review targets to what OIG found. The practical effect of a work plan item is felt after it closes, not during.

Which gives you a specific, unusual advantage: you know roughly what the findings will look like before they are published, because eight audits in the same series have already been completed and the error categories have not moved. Billing and coding. Face-to-face. Unsupported skilled need. If you tighten only those three, you will have addressed most of what is coming.

Our audit-ready healthcare contact center checklist is built around that idea — producing evidence on demand rather than assembling it under deadline.

SurfacerIQ sits in the category of systems that make the conversation layer of an agency retrievable: what was said on intake, scheduling and physician-office calls, structured so it can be located and produced rather than reconstructed from memory. It does not replace your clinical record. It closes the gap between the record and the conversation that produced it.

If pulling ten episodes took you longer than it should have, that is the finding. Talk to us.

OIG Is Medically Reviewing Home Health Documentation Right Now