Skilled Therapy Documentation

Harmony Healthcare International (HHI) integrity audits assist facilities in detecting, deterring and preventing Medicare fraud and abuse in response to facility concerns.

Harmony HealthCARE Specialists ensure that facilities are appropriately billing through an intensive on-site audit including MDS coding review, staff interviews, UB-04 claims review, as well as medical record documentation review.

Mock RAC (Recovery Audit Contractor) Audit (Two Day): Mock RAC audits generates a compliance rating for providers through clinical and documentation review related to therapy services and related MDS and billing procedures. Harmony HealthCARE Specialists will recommend systems to ensure compliance through Medicare Part A claims analysis, MDS coding assessment, therapy and nursing documentation analysis, UB-04 review as well as ICD-10 coding review.

The role of auditing and monitoring goes hand in hand with an organization’s compliance plan and is the mechanics of operating the program after other steps have been accomplished. Reliable auditing and monitoring includes all aspects of facility operations and takes into consideration the compliance program. Harmony Healthcare International (HHI) can assist with development of effective auditing and monitoring processes which are reliable, workable and produce results that enhance processes, outcomes and systems and include some of these basic elements:

  • Specifically identify and target what will be monitored
  • Identify specific action steps of the monitoring process for what will be audited
  • Identify a communications plan for how intelligence gathered from auditing and monitoring will be shared and used within the organization

The results from regular auditing creates data that can be used to track successful implementation of initiatives built around areas of risk identified in the risk assessment and described in the Compliance Plan.  The data is then used to adjust processes that directly influence the identified risk area initiative performance and ensure that providers know if they complying with substantive laws, policies and procedures.  These results are the basis for Annual Compliance Plan reporting to the Board of Directors.

How can Harmony Healthcare International (HHI) help?

Harmony HealthCARE Specialists assist providers in reviewing medical records to ensure that the provision of skilled rehabilitation therapy is: 

  • Delivered pursuant to an individualized plan of care; 
  • Consistent with the nature and severity of the resident’s and/or patient’s individual illness or injury;
  • In compliance with accepted standards of medical practice; 
  • Reasonable and necessary given the resident’s and/or patient’s condition and plan of care to improve his or her condition, prevent or slow deterioration of his or her condition, or restore the his or her prior levels of function; and 
  • Limited to services that are inherently complex and require the skills of physical, speech, or occupational therapists, among other types of professionals; 
  • Complies with Medicare program requirements relating to the tracking of therapy minutes (e.g., only includes services that are inherently complex and require the skills of physical, speech, or occupational therapists, among other types of professionals; appropriately accounts for group and concurrent therapy); 
  • Complies with all Medicare and the System Facilities requirements relating to the documentation of medical records;
  • Obtains an assessment, by a physician, of the resident’s and/or patient’s need for skilled therapy and that the skilled services will improve his or her condition, prevent or slow deterioration of his or her condition, or restore his or her prior levels of function; 
  • Assign individuals to conduct the Therapy Systems Assessment who have expertise in the Medicare requirements relating to rehabilitation therapy in skilled nursing facilities and in the general requirements of the Federal health care program(s)
  • Assign individuals to conduct the MDS Review who have expertise in the MDS requirements, Resource Utilization Group determination, claims submission, and other requirements of the Medicare Prospective Payment System for skilled nursing facilities and in the general requirements of the Federal health care program(s) from which the System Facilities seek reimbursement; 
  • Assign individuals to design and select the MDS Review sample who are knowledgeable about the appropriate statistical sampling techniques;
  • Assign individuals to conduct the coding review portions of the MDS Review who have a nationally recognized MDS or Resident Assessment Instrument certification and who have maintained this certification (e.g., completed applicable continuing education requirements)

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