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Ankota: Home Care Next Generation Blog

Will Fingerprinting be a Deterrent Against Home Health Fraud?

Elizabeth Hogue is an attorney who specializes in the home health industry. Her email articles alwaus present a well-written, no-nonsence representation of the facts.  She also holds seminars on how to get referrals legally (and in these seminars she provides advice to providersHome Care Lawyer who aren't being referred by their local hospitals.)

Her most recent piece, shown in its entirety below, describes how the government is requiring Home Care Owners to have fingerprints on file.  


The Centers for Medicare and Medicaid Services (CMS) issued MLN Matters Number SE1417 on April 11, 2014.  This Special Edition MLN Matters is intended for providers and suppliers who submit claims to Durable Medical Equipment (DME) Medicare Administrative Contractors (MACs) and Home Health and Hospice MACs for services provided to Medicare beneficiaries.  CMS makes it clear in this article that it will begin fingerprinting all owners of these types of providers with a 5% or greater ownership interest.  The ultimate goal is to fingerprint all owners with a 5% or greater ownership interest in all providers or suppliers in the high risk category that receive reimbursements from the Medicare Program. According to CMS, the implementation of fingerprint-based background checks as part of enhanced enrollment screening of providers is based on Section 640 of the Affordable Care Act (ACA).


When fully implemented, the fingerprint-based background check will be required for all individuals with a 5% or greater ownership interest in a provider or supplier that falls under the high risk category.  The high level of risk category appliesfingerprinting home care owners to all providers and suppliers who are newly enrolling DME suppliers or home health agencies.  This category will also apply to providers and suppliers who are elevated to the high risk category in accordance with enrollment screening regulations.


Fingerprint-based background checks will be implemented beginning in 2014.  Providers and suppliers subject to fingerprinting will receive notification of the requirements from their MAC.  The MACs will send notification letters to providers and suppliers that include a list of all owners with a 5% or greater ownership interest who are required to be fingerprinted.  Letters will be mailed to providers' or suppliers' correspondence addresses and special payments addresses on file with Medicare.  Individual fingerprinting will normally be required only once, but CMS reserves the right to request additional fingerprints, if needed. Owners will have thirty days from the date of notification letters to be fingerprinted.  Providers and suppliers that find discrepancies in the list of owners sent to them by the MACs should communicate the discrepancies and take appropriate action to update enrollment records to reflect corrected ownership information.


Notification letters will include contact information for the Fingerprint-Based Background Check Contractor (FBBC).  Individuals required to be fingerprinted are required to contact the FBBC prior to being fingerprinted to ensure that fingerprints are accurately submitted to the Federal Bureau of Investigation (FBI) and that the results are properly transmitted to CMS.  Providers and suppliers subject to fingerprinting will be able to contact the FBBC by telephone or by accessing the FBBC's website.  Contact information for the FBBC will be included in notification letters sent by the MACs.  The FBBC will provide at least three locations convenient to individuals' locations where they can be fingerprinted.  One of the locations must be a local, state, or federal law enforcement facility.


Individuals required to be fingerprinted must bear all expenses related to being fingerprinted.

Home Care Best Practices 

CMS encourages providers and suppliers to provide fingerprints electronically, but CMS will accept the FD-258 card instead.  FD-258 cards submitted will be converted to electronic submissions to the FBI by the FBBC. 


Fingerprints will be sent to the FBI for processing.  The FBI will compile background history based on fingerprints within twenty-four hours of receipt and will share the results with the FBBC.  The FBBC will review each record and make recommendations to CMS regarding fitness.  CMS will assess recommendations from FBBC and make final determinations.  CMS may deny enrollment applications or revoke existing Medicare billing privileges based on its final determinations of the results of fingerprint background checks.


Providers and suppliers regularly face a number of hurdles in the enrollment process.  The above addition to the process is bound to increase providers' frustration.  Meticulous compliance will be the name of the game! 
©2014 Elizabeth E. Hogue, Esq.  All rights reserved.

What Does this Mean for Home Health, Hospice, and DME Providers?

From my perspective, this sends two messages.  One is that CMS is being very serious about the identities of the busines owners that it deals with in post acute care.  The second takeaway for me, since fingerprinting is generally associated with criminal activity, is that they're sending a warning to agencies considering fraudulent actions.  All of the home care agencies I've dealt with have been fully-reputable and lawful in their practices, so I personally applaud all efforts to weed out the bad apples.


Ankota provides software to improve the delivery of care outside the hospital, focusing on efficiency and care coordination. Ankota's primary focus is on Care Transitions for Reeadmisison avoidance and on management of Private Duty non-medical home care. To learn more, please visit www.ankota.com or contact Ankota.


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