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Healthcare Corporate Compliance: Keys to Assembling A Sound Program

Harmony 2014

A Corporate Compliance Program is the Long Term Care provider's formalized and proactive approach towards detecting fraud, abuse, and waste of precious company resources.  Exact regulations for this important program have not yet been crystallized, so many facilities are left wondering what, if anything, should be implemented immediately.  Harmony (HHI) recommends taking a hands-on approach to Corporate Compliance.  Although the impending regulations remain to be seen, a Corporate Compliance Program is of benefit to every facility.

Skilled Therapy Documentation & The Importance of Weekly Progress Notes

Harmony 2014

Increased efforts to audit Medicare records by Medicare Administrative Contractors (MACs), as well as other subcontractors of CMS, should make all providers very conscientious regarding skilled documentation that without question supports the need for daily skilled care.  

The Importance of Preventing Artificially Low Case Mix Reimbursement

View Matt McGarvey's LinkedIn profile

The New York State Executive Budget, as proposed by Governor Cuomo, is considering a 2% Cap on increases in New York’s Skilled Nursing Facilities’ Case Mix Index.  The effect on SNF provider’s Medicaid reimbursement (already the largest gap between reimbursement and cost in the nation) could be significant.

New York State Transitions to Medicaid Managed Care Plan March 1st

2014 SNF Interidisciplinary Symposium

Effective March 1, 2014, all eligible beneficiaries over the age of 21 in New York City, Nassau, Suffolk and Westchester counties, in need of long term placement in a nursing facility, will be required to join a Medicaid Managed Care Plan (MMCP) or a Managed Long Term Care Plan (MLTCP).  The rest of New York State is scheduled to begin transitioning this coming September for both dual and non-dual eligible populations and all upstate counties will be phased in by December 2014.

Updated Medicare Benefit Policy Manual

PEPPER Analysis

The Centers for Medicare & Medicaid Services (CMS) revised Chapter 8 ”Coverage of Extended Care (SNF) Services Under Hospital Insurance” with implementation on January 7, 2014. This manual is the Medicare authoritative publication for making skilled coverage decisions and ensuring documentation supports the care provided. This source document is utilized by Medicare reviewers in detailing why a claim for skilled rehabilitation or nursing services is denied.

Skilled Rehabilitation Treatment Planning for Seating and Positioning

PEPPER Analysis

A common conundrum for licensed therapy professionals who specialize in treatment of the long term care patient residing in a nursing home is how to best address seating and postural deficits. Determining the type of seating device is one hurdle, but an even bigger obstacle can be devising goals that are patient related, functional and reasonable for a set time frame. Orthotic fitting and training for the fragile elderly patient is an art form and requires the unique skills of an experienced geriatric therapist.

Establishing the Medicare Denial Management Process

PEPPER Analysis

It is common practice for facilities to receive communications from Medicare review agencies requesting proof of the provision of skilled services.  Understanding the process and managing these inquiries in a timely and detailed manner is critical in order to minimize recoupment of Medicare Revenue. 

2014 PEPPER Report Update: From Snail Mail to Electronic Delivery

TMF Health Quality Institute announced that effective January 1, 2014 they will no longer resend copies of SNF PEPPERs (version Q4FY12) which were initially mailed to all Skilled Nursing Facilities on August 30, 2013.


10 Tips for a Better Case Mix Index

Case Mix System by State

When the MDS is completed, it calculates a clinical score (RUG level, Resource Utilization
Group) which impacts the direct care costs under the Case Mix reimbursement system. The notion is that the higher the amount of resources rendered to care for the patient/resident, the higher the reimbursement level. There are different types of RUG systems and each state has the ability to create its own system.

The MDS is a very dynamic, complex tool used for resident/patient assessment.  One can only imagine the vast opportunity for error when completing said tool. Over 1,000 points of information, of which 108 plus points yield one of 34 RUG levels. In order to mitigate inaccuracy and ultimate underpayment of resources, the following 10 tips may help in the quest for precision.


Speech-Language Pathology CPT Codes Changes Effective January 1, 2014

PEPPER Analysis

Effective January 1, 2014, the commonly used CPT code 92506 for evaluation of speech, language, voice, communication, and/or auditory processing will be deleted and replaced with four new, more specific evaluation codes. This code is frequently utilized by Speech-Language Pathologists in the Skilled Nursing Facility setting.

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