With the upcoming holidays comes increased confusion related to the Medicare beneficiary’s ability to enjoy a temporary visit home to participate in holiday celebrations with his or her loved ones. While many Medicare beneficiaries are too acutely ill to leave the facility even for a brief home visit, there are no regulations preventing Medicare beneficiaries who are physically able, from enjoying a temporary home visit to participate in the holiday festivities.
According to the Medicare Benefit Policy Manual, “An outside pass or short leave of absence for the purpose of attending a special religious service, holiday meal, family occasion, going on a car ride, or a trial home visit, is not, by itself evidence that the individual no longer needs to be in a SNF for the receipt of required skilled care.”
October 1, 2011 CMS instituted changes to the PPS Assessment schedule.The changes in the Assessment Reference Date (ARD) windows impacted the coding and capture of services during the look back period. As always, but now more than ever, facilities must maintain optimal organization of patient specific information.
With the spiraling cost of health care in the United States, it is critical to demonstrate the effectiveness and efficiency of therapy treatment. As payers, health care systems and the public question the efficacy and cost effectiveness of rehabilitation, objective documentation is becoming more important. Therapists must have a more scientific basis for their practice. Evidence based treatment is indeed best practice. Referrals are increasingly based on objective, value-based criteria including metric-driven rehabilitation performance, rates of successful home discharges, re-hospitalization rates and patient experience ratings.
Today, I want to talk about Assessment Reference Date selection or ARD Management. One of the key factors for selection of ARD is the communication between the MDS Coordinator and the therapy department. Whether you have a Rehab Manager or somebody within the department who is designated to communicate with the MDS Coordinator, it is significantly important to schedule a time to meet regularly. Truly, here at Harmony, we feel as though ARD management should be something that occurs on a daily basis so that MDS and Rehab are discussing any time that there is a change in the level of care provided to a patient through the therapy minutes. Potentially, a patient could get sick and miss therapy minutes or maybe a patient is doing exceptionally well and therapy is able to provide additional minutes to that patient. The bottom line is that every day there should be some type of communication between MDS and Therapy to make sure that you are capturing the most accurate level of service provided to the patient. This will in turn allow the facility to receive the most accurate level of reimbursement for the services that you are providing. This hopefully will spur some discussion between MDS and Rehab.
Today I want to talk about the Change of Therapy (COT) Other Medicare Required Assessment (OMRA). There are a couple of major points that should be kept in mind when considering whether COT OMRA needs to be completed. For one, how do we manage our therapy case load to prevent continually needing to complete an off schedule assessment for our PPS or our Medicare Part A patients? Always remember the COT OMRA is generated because there needs to be a change in the level of payment. This is due to the level of therapy intensity that is being provided. So, if you have a PPS Assessment and it generates a nursing RUG classification, a nursing RUG score is being paid for a particular PPS Assessment. If Therapy is involved, you are monitoring your COT Assessment Reference Dates, and the change in therapy intensity decreases, you do not need to complete a COT OMRA (if you are being paid at nursing RUG level). Many times it is forgotten that this is both clinically related as well as payment related.
Today’s Medicare Minute we are going to talk about interviews on the MDS. At the MDS National Convention CMS stressed the importance of interview accuracy on the MDS. Unlike the MDS 2.0, MDS 3.0 has four structured interviews. This includes the PHQ-9, which looks at the patient’s mood, The BIMS, which looks at the patient’s cognition, Activity preferences, and pain. Each one of these interviews has a specific timeline in which they need to be completed. The PHQ-9 should be honored before the ARD, the BIMS has a seven day look back, the activity preference interview has a seven day look back, and the pain interview has a five day look back. In completing your interviews, you want to make sure you read the RAI Manual carefully, including Appendix D, because there are great tips and guidelines to make sure you get the most out of your interview process. If you are signing sections that have interviews you might have to sign the MDS twice, once before the ARD for the interview and again after the ARD for the rest of the section. Whatever your process is, you want to make sure that you have good systems set up so that not only are you getting the most out of your interview, but that you have got ARDs well managed so that interviews are timely.
Today we will be discussing the Medicare meeting, otherwise known as the beneficiary review meeting. This meeting is set up so that the interdisciplinary team can discuss the clinical status of a patient and whether that patient continues to meet the criteria for skilling under their Medicare Part A benefit. This meeting provides an opportune time to review the Medicare Part B beneficiaries or your managed care patients during this meeting. The goal of the meeting is not to focus on when the patient is going to be discharged. This is not a discharge planning meeting, the meeting is designed to review what the skilling criteria or the needs on a daily basis of the patient from nursing and from therapy. HHI recommends that the entire interdisciplinary team attend this meeting and that each member of the team be aware of what they are going to be reporting on during the meeting. For example, the business office would be discussing how many days the patient has used in their benefit period or how many days the patient has left. MDS may be discussing what the potential selected ARD date is. As well, MDS may discuss ADL assistance provided to the patient to make sure that team members are in agreement with the level of assistance provided to assure levels are accurately reflected on the MDS. Nursing should be talking about why the patient requires daily skilled care and therapy should talk about the patient’s status in relationship to their ability to continue to provide daily skilled care to the patient. Again, this meeting is so that the team can assure that the facility is accurately utilizing the patient’s Medicare Part A benefit.