a publication of the health care compliance association SEPTEMBER 2018

Similar documents
MLN Matters Number: MM6699 Related Change Request (CR) #: 6699

Inpatient Rehabilitation Facilities. Navigating the Sea of Requirements

Medicare Part A Update

Updates to the erehabdata PAS Tool & Referrals Outcomes Reports

Tips for Successful Completion of a Continued Stay Request. Clinical Webinars for Therapy February 2012

Regulatory Compliance Risks. September 2009

AHLA. Z. New Rules: Hospital Patient Status, Observation, Part B Billing for Denied Inpatient Admissions

Post Acute Medical. Debra R Riegel, RN. Presented to: American Hospital Association

Audit to Protect Your Margins

Determining the Appropriate Inpatient Rehabilitation Candidate

Compliance. TODAY June High-level stress: Remembering the first OIG Medicare Compliance Review an interview with Tessa Lucey.

601-Audit Plan for Medicare s Shared Visit Rule

2018 UDSmr Webinar Series

5101: Home health services: provision requirements, coverage and service specification.

Medicare General Information, Eligibility, and Entitlement

FY 2014 Changes to Medicare Inpatient Admission and Reimbursement Standards: CMS s Two Midnight Rule and the Revised Part A to Part B Rebilling Policy

HCCA South Central Regional Annual Conference November 21, 2014 Nashville, TN. Post Acute Provider Specific Sections from OIG Work Plans

Reviewing Short Stay Hospital Claims for Patient Status: Admissions On or After October 1, 2015 (Last Updated: 11/09/2015)

State of Connecticut REGULATION of. Department of Social Services. Payment of Behavioral Health Clinic Services

Precertification: Overview

Dean Health Plan Physical Medicine Overview

Reference Guide for Hospice Medicaid Services

Benefit Criteria for Outpatient Observation Services to Change for Texas Medicaid

Patient Driven Payment Model (PDPM) and the MDS: A Total Evolution of the SNF Payment Model

General Inpatient Level of Care: Managing Risks

Navigating Therapy Compliance Requirements Across The Continuum. Objectives. Therapy is Occurring Everywhere!

Therapies (e.g., physical, occupational and speech) Medical social worker (MSW) 3328ALL0118-F 1

CURRENT OIG ENFORCEMENT INITIATIVES: A ROAD MAP FOR HIGH RISK COMPLIANCE AREAS

General Information. Overview. Purpose. Table of Contents

Seema Verma Centers for Medicare & Medicaid Services Department of Health and Human Services Attn: CMS-1696-P P.O. Box 8016 Baltimore, MD

Blue Choice PPO SM Provider Manual - Preauthorization

ABOUT FLORIDA MEDICAID

Residents Have a Right to Return After Hospitalization

Reference materials are provided with the criteria and should be used to assist in the correct interpretation of the criteria.

hospic Hospice Care 1 Hospice care is a medical multidisciplinary care designed to meet the unique needs of terminally ill individuals.

Changes to Medicare Inpatient Admission and Reimbursement Standards: CMS s Two Midnight Rule and the Revised Part A to Part B Rebilling Policy

Medicare: This subset aligns with the requirements defined by CMS and is for the review of Medicare and Medicare Advantage beneficiaries

STROKE REHAB PROGRAM

State Operations Manual. Appendix M - Guidance to Surveyors: Hospice - (Rev. 1, )

CMS IPPS 2014 Final Rule: Physician Education on Observation Status and 2-Midnight Rule

See page 16. Drug diversion in healthcare facilities, Part 1: Identify and prevent. Erica Lindsay

AHLA. GG. Physician Orders. Timothy P. Blanchard Blanchard Manning LLP Orcas, WA

State of California Health and Human Services Agency Department of Health Care Services

HOSPICE TARGETED PROBE & EDUCATE Melinda A. Gaboury, COS C Healthcare Provider Solutions, Inc.

CATEGORY 4 - OASIS DATA SET: FORMS and ITEMS. Category 4A - General OASIS forms questions.

General Who is National Imaging Associates, Inc. (NIA)?

2014 Hospital Admission Criteria

POLICY SUBJECT: POLICY:

Page 1. I. QUESTIONS ABOUT HETs SYSTEM


Mobile Medical Review Team Observation Services & the 2 Midnight Rule. The Audio and/or Video Recording of this Educational Session is Prohibited

CMNs Chapter 4. Chapter 4 Contents

Clinical Medical Policy Department Clinical Affairs Division DESCRIPTION

Review Process. Introduction. InterQual Level of Care Criteria Long-Term Acute Care Criteria

Executive Summary, December 2015

ABOUT AHCA AND FLORIDA MEDICAID

Department of Assistive and Rehabilitative Services Early Childhood Intervention Services Medicaid Billing Guidelines Effective: October 1, 2011

Understanding the PEPPER

POLICY AND PROCEDURE DEPARTMENT:

National Imaging Associates, Inc. (NIA) Frequently Asked Questions (FAQ s) For NH Healthy Families Providers Post Service Therapy Review Program

Subject: Updated UB-04 Paper Claim Form Requirements

A SUMMARY OF MEDICAID REQUIREMENTS AND RELATED COA STANDARDS

Chapter 11 Section 3. Hospice Reimbursement - Conditions For Coverage

Home Health Eligibility Requirements

Outpatient Observation Services

Home Health Medical Record Audit Form. Certification. Does the plan of care and

CAH SWING BED BILLING, CODING AND DOCUMENTATION. Lisa Pando, Sr. Consultant GPS Healthcare Consultants

The Society for Cognitive Rehabilitation, Inc th Ave NE, Bellevue, WA 98004, USA

OMIG AUDIT PROTOCOL- CERTIFIED HOME HEALTH CARE (CHHA) - Effective XX/XX/XX

Is your Home Health Agency ready for the Final Rule to the Conditions of Participation?

2017 FOCUSED ON DOCUMENTATION NECESSITIES & PRE-CLAIM REVIEW

ATTACHMENT I. Outpatient Status: Solicitation of Public Comments

IMAGES & ASSOCIATES O UR S ERVICES OPERATIONAL REVIEW AND ENHANCEMENT

Chapter 4 Health Care Management Unit 3: Requesting an Authorization

Documentation Requirements for Timed Therapeutic Procedures Reimbursement Policy Annual Approval Date. Approved By

CMS Observation vs. Inpatient Admission Big Impacts of January Changes

The Medicare Appeals Process Is It Working in 2013?

Care Plan Oversight Services and Physician Services for Certification

Medicare 101. Lisa Satterfield, ASHA director, health care regulatory advocacy Neela Swanson, ASHA director, health care coding policy

1.2.4(a) PURCHASE OF SERVICE POLICY TABLE OF CONTENTS. General Guidelines 2. Consumer Services 3

Presented by: Arlene Maxim, RN-Founder A.D. Maxim Consulting, LLC.

CONTRACT YEAR 2011 MEDICARE ADVANTAGE PRIVATE FEE-FOR-SERVICE PLAN MODEL TERMS AND CONDITIONS OF PAYMENT

Inpatient Psychiatric Facility (IPF) Coverage & Documentation. Presented by Palmetto GBA JM A/B MAC Provider Outreach and Education September 7, 2016

Compliant Documentation for Coding and Billing. Caren Swartz CPC,CPMA,CPC-H,CPC-I

Payment Policy: 30 Day Readmission Reference Number: CC.PP.501 Product Types: ALL

MEDICARE HOME HEALTH COVERAGE

PERSON CENTERED CARE PLANNING HONORING CHOICE WHILE MITIGATING RISK

Cognitive Emotional Social Behavioral functioning

TABLE OF CONTENTS. Therapy Services Provider Manual Table of Contents

INTERQUAL REHABILITATION CRITERIA REVIEW PROCESS

SNF Determinations of Non-Coverage Denial Letters, ABNs & Expedited Determinations

REGULATION, ACCREDITATION, AND PAYMENT PRACTICE GROUP (June, July, August 2004)

DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Medicare & Medicaid Services. Discharge Planning

COPs 2018 Now is the Time. HCAC 2017 Conference PreConference 2017 The Crag Business Group, Inc.

Presentation Overview

Observation Care Evaluation and Management Codes Policy

NEW YORK STATE MEDICAID PROGRAM REHABILITATION SERVICES PROCEDURE CODES & FEE SCHEDULE

50938 Federal Register / Vol. 78, No. 160 / Monday, August 19, 2013 / Rules and Regulations

NURSING FACILITIES: FRIENDS OR FOES? Marie C. Berliner Joy & Young, LLP Austin, Texas (512)

Standards of Practice & Scope of Services. for Health Care Delivery System Case Management and Transitions of Care (TOC) Professionals

Transcription:

hcca-info.org Compliance TODAY a publication of the health care compliance association SEPTEMBER 2018 Strengthening the relationship between DOJ attorneys and compliance professionals an interview with Michael D. Granston This article, published in Compliance Today, appears here with permission from the Health Care Compliance Association. Call HCCA at 888.580.8373 with reprint requests.

by Danielle C. Gordet, JD, MPH, CHC Rehabbing critical documentation processes in your inpatient rehabilitation facility Inpatient rehabilitation facilities are required to complete four distinct medical record components for the services to be considered reasonable and necessary. The rehabilitation physician has specific obligations during the preadmission screening process, which must occur prior to the patient s admission. A post-admission physician evaluation must be completed within 24 hours of a patient s admission. The rehabilitation physician must develop an individualized overall plan of care and document it in the medical record. Interdisciplinary team meeting documentation must include evidence that certain discussion elements were satisfied. Danielle C. Gordet (dgordet@gmail.com) is a Director of Compliance, in the Office of Compliance & Ethics at Jackson Health System, in Miami, FL. Gordet It is imperative to ensure that your inpatient rehabilitation facility (IRF) is meeting the Center for Medicare & Medicaid Services (CMS) requirements. This article will walk you through the requirements and discuss certain tips to keep in mind as you work with your hospital partners to ensure they understand how to maintain compliance. (See Table 1 on page 81 for a quick summary of the required documentation.) Importance of documentation All healthcare compliance professionals know that documentation matters. This message is ingrained in us from the beginning of our careers. It is therefore no surprise that the Office of Inspector General (OIG) Supplemental Compliance Program Guidance for Hospitals states: It is axiomatic that all claims and requests for reimbursement from the Federal health care programs and all documentation supporting such claims or requests must be complete and accurate... 1 The OIG s continued emphasis on the importance of documentation is highlighted when it comes to IRFs, which must meet specific documentation requirements for care to be considered reasonable and necessary. For instance, the Medicare Benefit Policy Manual instructs all Part A and Part B Medicare Administrative Contractors (MACs) conducting IRF reviews to consider the documentation contained in a patient s IRF medical record when determining whether an IRF admission was reasonable and necessary; in particular, evidence related to the preadmission screening, the post-admission physician evaluation, and the overall plan of care. 2 The OIG signaled increased scrutiny in the area of IRF documentation by including a Fiscal Year (FY) 2016 active Work Plan Item to review whether IRFs nationwide billed claims in compliance with Medicare documentation and coverage requirements. 3 The Work Plan Item is expected to be issued in FY 2018. While we wait for the results, the OIG continues to 888.580.8373 hcca-info.org 77

release compliance reviews of IRFs that have failed to satisfy documentation requirements. In one recent review, the OIG found the hospital billed 20% of the audited IRF claims incorrectly, because they did not comply with Medicare documentation requirements. 4 As will be discussed in greater detail below, CMS requires that the services for each patient for which the IRF seeks payment be reasonable and necessary. In order for these services to be considered reasonable and necessary, the patient s medical record at the IRF must contain the following four elements. 5 1. Comprehensive preadmission screening The preadmission screening is of the utmost importance, because this document paints the picture of the patient s status before he/she was admitted to the IRF and the reasons that led the IRF clinicians to determine that the admission was reasonable and necessary. 2 Documentation of the preadmission screening must be retained in the patient s medical record and must include 6 : the patient s prior level of function (prior to the event causing the need for intensive rehabilitation therapy), the expected level of improvement, the expected length of time to achieve the level of improvement, an evaluation of the risk for clinical complications, the conditions that caused the need for rehabilitation, the therapies needed, the expected frequency and duration of IRF treatment, the anticipated discharge destination, and any anticipated post-discharge treatments. Although a physician extender may complete the preadmission screening, a rehabilitation physician (defined as a licensed physician with specialized training and experience in inpatient rehabilitation 7 ) is required to review and document his/her concurrence with the findings and results of the preadmission screening prior to the patient s admission to the IRF. The preadmission screening must typically be conducted within the 48 hours immediately preceding a patient s admission to an IRF; however, if all of the required preadmission screening elements were included in a screening that occurred more than 48 hours before admission, CMS permits such screenings so long as an update occurs in person or by phone to update the patient s medical and functional status within the 48 hours immediately preceding the IRF admission and is documented in the patient s medical record. 5 CMS gives IRFs the freedom to decide how they will ensure that all of the preadmission screening elements are included in the patient s medical record. MACs are told to focus on ensuring that the screenings are complete, accurate, and support the appropriateness of the IRF admission and not to critique how the process that was used to make those determinations was organized. 2 When reviewing whether your IRF has a strong process in place, keep in mind that CMS does not believe check-off lists are an acceptable form of documenting the preadmission screening. 8 Accordingly, merely having a form with yes/no checkboxes for the various elements of the preadmission screening is not appropriate without an accompanying narrative explanation. 9 In addition, it is important to ensure that each preadmission screening captures the rehabilitation physician s signature (concurring with the findings of the screening), as well as the date and time of his or her signature. 6 A dated and timed signature by the rehabilitation physician with one sentence saying that he or she has reviewed and concurs with the findings and results of the preadmission 78 hcca-info.org 888.580.8373

screening is acceptable. 9 The OIG has denied IRF documentation of preadmission screenings when the claims lacked signatures, dates, and/or times when the screenings were performed or approved, because lacking these the OIG was unable to determine whether the screenings or screening reviews were performed within the 48 hours immediately preceding admission. 6 2. Post-admission physician evaluation (PAPE) A PAPE must be completed by a rehabilitation physician within 24 hours of the patient s admission to the IRF and be retained in the patient s medical record. 5 PAPE documentation must (1) describe the patient s status on admission to the IRF; (2) serve as a comparison with the information noted in the preadmission screening; (3) form the basis for the patient s overall individualized plan of care; 5 (4) identify any relevant changes that have occurred since the preadmission screening; (5) include a documented history and physical exam, as well as a review of the patient s prior and current medical and functional conditions and comorbidities; and (6) support the medical necessity of the IRF admission. 6 It is important to note that although CMS has said that a resident or physician extender may complete the history and physical exam, the rehabilitation physician must visit the patient and complete the other PAPE requirements. 8 If, while completing the PAPE, the rehabilitation physician determines that the patient s needs no longer support IRF admission, the IRF must immediately begin the process of discharging the patient to the appropriate level of care. 2 An IRF claim may be denied if even one part of the required information is missing from the PAPE documentation. For instance, OIG audits have denied claims for insufficient documentation when the rehabilitation physician completed the history and physical examination within 24 hours of admission, but failed to include additional required information, such as a comparison with the information noted in the preadmission screening documentation and an identification of any relevant changes that may have occurred since the preadmission screening. Additionally, it is important to ensure that the history and physical examination documentation includes the date and time it occurred. CMS has denied claims when the history and physical examinations are documented but fail to include evidence that they were conducted within 24 hours of admission. 6 3. Individualized overall plan of care (OPoC) The rehabilitation physician, with input from the interdisciplinary team (described later in this article), is required to develop the OPoC within four days of the patient s admission to the IRF. 5 The rehabilitation physician is responsible for integrating the information from the patient s preadmission screening, the PAPE, and other therapy assessments into the OPoC and documenting the OPoC in the patient s medical record. 2 The OPoC can be an extension of the preadmission screening and the PAPE it does not have to repeat all of the information that they contained. The rehabilitation physician is ultimately responsible for the admission decision to the IRF, but physician extenders may work in collaboration with the rehabilitation physician in developing the OPoC for the physician s approval and signature. 9 The OPoC must detail (1) functional outcomes; (2) discharge destination from the IRF; and (3) the patient s medical prognosis and anticipated interventions (i.e., physical, occupational, speech-language pathology, and prosthetic/orthotic therapies) required during the IRF stay, including expected (a) intensity (number of hours per day), (b) frequency (number of days per week), 888.580.8373 hcca-info.org 79

and (c) duration (total number of days during the IRF stay). 2 As with the other IRF requirements, CMS has given IRFs the leeway to develop their own processes to ensure that all the required elements are met. 2 It is important to note that the OIG has denied IRF claims where IRF personnel prepared and documented assessments within four days of the IRF admission, but the rehabilitation physicians did not develop and integrate this information into individualized overall plans of care and document them in the medical records. 6 Implementation of an interdisciplinary team approach IRFs are required to have an interdisciplinary team approach to treating patients. Documentation in the patient s medical record must demonstrate that weekly interdisciplinary team meetings occurred and consisted of the following team members, all of which must have current knowledge of the patient s medical and functional status: (1) rehabilitation physician, (2) registered nurse with specialized training or experience in rehabilitation, (3) a social worker or case manager (or both), and (4) a licensed or certified therapist from each therapy discipline involved in treating the patient. 5 CMS expects that all treating professionals from the required disciplines will be at every meeting or, in the case of an absence, send a designee of the same discipline in their stead who has knowledge of the patient. 2 The rehabilitation physician is responsible for leading the weekly meetings, the purpose of which are to implement appropriate treatment services; review the patient s progress toward stated rehabilitation goals; identify any problems that could impede progress towards those goals; and, where necessary, reassess previously established goals in light of impediments; revise the treatment plan in light of new goals; and monitor continued progress toward those goals. 5 MACs are instructed to review documentation of the interdisciplinary team meetings to ensure that the following information is also included in the medical record: (1) the names and professional designations of the participants in the team conference; (2) the occurrence of the meeting; (3) decisions made during the meeting (e.g., decisions regarding discharge planning and the need for adjusting treatment goals); and (4) concurrence by the rehabilitation physician with the meeting s results and findings. 2 Like the previous requirements, the OIG is less concerned about hospital processes as long as the medical record documentation includes sufficient information to support the occurrence of the team meetings and evidence that discussion of the required elements occurred. The OIG has denied claims where the rehabilitation physicians made only brief mention of team meetings in certain progress notes, which describe the daily status of the patients, and did not address additional requirements. 6 Takeaways Now is the time to take a good look at the IRF you work with to ensure that it is meeting the discussed CMS regulations. There are numerous documentation requirements, so make sure that you have a strong team in place to ensure compliance. Build a team that spans the hospital disciplines, gaining buy-in from all stakeholders involved, including IRF staff, Internal Audit, Information Technology, and hospital executives. By establishing a robust, multidisciplinary team to monitor and facilitate the documentation of all the requirements previously described, you will establish your best chance of remaining compliant with the varying rules and regulations and reduce claim denial rates. 80 hcca-info.org 888.580.8373

Table 1: Documentation Requirements for Inpatient Rehabilitation Facilities Elements Documentation Must Include Who Is Involved? Timing Tips Preadmission Patient s prior level of function Physician Extender may complete it Within Check Off Lists are not Screening Expected level of improvement 48 hours an appropriate way to Expected length of time to achieve level of improvement Rehab Physician must review and immediately document the screening s Evaluation of risk for clinical complications document concurrence with findings preceding elements Conditions that caused need for rehabilitation and results admission Therapies needed Screening must include Expected frequency and duration of IRF treatment date and time it occurred, Anticipated discharge destination and post-discharge treatments as well as Rehab Physician signature Post-Admission Description of patient s status on admission to IRF Resident or Physician Extender may Within 24 History and physical exam Physician A comparison with information noted in preadmission screening complete history and physical exam hours of documentation must Evaluation A basis for patient s OPoC admission include the date and time it ( PAPE ) Identification of any relevant changes since preadmission Rehab Physician must visit patient to IRF occurred screening and complete the other PAPE Documented history and physical exam, and a review of patient s requirements prior and current medical and functional conditions and comorbidities Support for medical necessity of IRF admission Individualized Patient s medical prognosis and anticipated interventions Physician Extender may work with Within 4 Rehab Physician may write Overall Plan required during IRF stay, including expected: Rehab Physician in developing OPoC days of out the OPoC or bring of Care Intensity (number of hours per day), for Rehab Physician approval and admission together individual plans ( OPoC ) Frequency (number of days per week), and signature to IRF of care from different Duration (total number of days during the IRF stay) treating disciplines and Functional outcomes Rehab Physician must approve and modify or add to them, as Discharge destination from IRF sign OPoC appropriate Interdisciplinary Evidence that meetings occurred weekly Must consist of the following Weekly Medical Record Team Approach Names and professional designations of team participants members, who must have current during IRF documentation must to Care Decisions made during meetings, including discussion of: knowledge of patient s medical and stay include sufficient Appropriate treatment services; functional status: information to support Patient progress toward stated rehab goals; Rehab Physician with specialized occurrence of meetings Identification of problems that could impede progress towards training and experience in rehab and evidence that goals; and, Registered Nurse with specialized discussion of required Where necessary, reassessment of previously established goals training or experience in rehab elements occurred in light of impediments, revision of treatment plan in light Social Worker or Case Manager of new goals, and monitoring of continued progress toward (or both) those goals Licensed or Certified Therapist Evidence of concurrence by Rehab Physician with meeting from each therapy discipline results and findings involved in treating patient The views expressed herein are those of the author and do not necessarily reflect the views of Jackson Health System. The information contained herein is not intended to convey or constitute legal advice and is not a substitute for consulting a qualified attorney. You should not act upon any such information without first seeking qualified counsel on your specific matter. 1. HHS OIG: Supplemental Compliance Program Guidance for Hospitals; 70 Fed. Reg. 4858, 4859. January 31, 2005. Available at https://bit.ly/2m0w1eu 2. Centers for Medicare & Medicaid Services (CMS): Medicare Benefit Policy Manual, CMS Pub. 100-02, Chap. 1, Sec. 110 (Rev. 234, March 10, 2017). Available at https://go.cms.gov/2vjquee 3. HHS OIG: Active Work Plan Items, Inpatient Rehabilitation Facility Payment System Requirements. Available at https://bit.ly/2mwsr5p 4. HHS OIG: Medicare Compliance Review of Memorial University Medical Center. February 2018. Available at https://bit.ly/2mt99xw 5. 42 CFR 412.622 (Basis of payment). Available at https://bit.ly/2nv9rfh 6. HHS OIG: Norwalk Hospital Did Not Comply with Medicare Inpatient Rehabilitation Facility Documentation Requirements. February 2013. Available at https://bit.ly/2ubeog6 7. 42 CFR 412.622(a)(3). Available at https://bit.ly/2nv9rfh 8. CMS: Inpatient Rehabilitation Therapy Services: Complying with Documentation Requirements. July 2012. Available at https://go.cms.gov/2kshkjl 9. CMS: Follow-up Information from the November 12 Provider Training Call. November 12, 2009. Available at https://go.cms.gov/2nstcig 888.580.8373 hcca-info.org 81