Compliance Corner

Updates! A Look Back, What’s Happening Now and a Look into the Immediate Future

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Compliance Corner

By Brian del Poso, Associate Compliance Partner

With just about three-fourths of the year completed, it’s a good time to provide an update on where we stand compliance-wise and what’s on the horizon for the rest of the year. Therapy documentation and technical accuracy has come a long way, so kudos to all of you. There are still a few areas, however, that we can pay closer attention to. These items will sound familiar as they have been identified in years past and have improved, but we definitely still need to consistently get better at:

  1. Physical agent modalities documentation
  2. Co-tx documentation
  3. Personalized clinical assessment in Progress Reports
  4. Documentation and justification for billing patient education, especially when residents are difficult and/or refusing treatment

Again, there has been improvement in these areas, but there’s definitely a high ceiling for growth. I encourage you all to seek further education and training in these documentation areas. The easy way out would be to look at some of these things and just say, “Well, we just won’t do co-tx anymore,” or “We don’t use physical agent modalities often, so…,” but the easy way out isn’t who we are. Let’s invest in each other and in the spirit of our core value of PASSION FOR LEARNING, and utilize the therapy resources, POSTettes, and compliance partners we have at our disposal to move ourselves forward.

Part A MSCAs were on a bit of a hiatus as the IRO summer season began, but they are starting up again as we speak. With that said, here’s a YTD look at some of our top-performing facilities from the MSCAs. Congrats and keep it up!

 

2018 MSCA Overall Scores 2018 MSCA Therapy Dept. Scores
Facility Top 5 Facility Top 5
Timberwood (Keystone) 99.27% The Grove (Signum) 100.00%
Panorama Gardens (Signum) 99.11% Golden Acres (Keystone) 99.53%
Brookside (Signum) 99.04% Northbrook (Signum) 99.53%
Claremont (Signum) 98.45% Atlantic (Signum) 99.43%
Sea Cliff (Signum) 98.39% Brookside (Signum) 99.40%

If you’d like to know where you rank within your company, please reach out to your local compliance partner, and we will get that information out to you.

Coming up in Q4, we’ll be wrapping up any leftover MSCAs, and similar to recent years, we will also be starting up Part B MSCAs. As a reminder, not all facilities will receive a Part B audit this year. Facilities chosen for Part B audits will be dependent on the size of your Part B program. Essentially, if your YTD Part B revenue hits a certain threshold, you’ll be in the pool for a Part B audit. We’re currently working on the threshold to see how much revenue makes sense for a cutoff point, so more to come from your local compliance partners.

Lastly, I’m sure you all have heard or seen the emails about our Independent Review Organization (IRO) audits. We’re not out of the woods yet and still have the remote portion coming up, but we wanted to give a shoutout to this year’s on-site facilities (Legend Oaks Kyle, Golden Acres, Rehab Center of Des Moines, Grand Oak, Redmond, HCR CO Springs, Heritage Park, Brookfield) for doing such an awesome job in our very last CIA and IRO year!

Ownership!

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The land swelled below the wing of the plane in gentle shades of green and brown, revealing ample squares defining crops, and the perimeter of a small community where various creeks meander through town before combining to become the Walla Walla River, which drains into the Columbia River about 30 miles west of town. Park Manor Rehabilitation Center is nestled in the farmlands of eastern Washington.

One sweltering hot morning, Sonya, DOR and Zewdi, DON and the IDT team calmly evacuated over two dozen residents to the dining area to preempt any issues with dehydration in a seamless flow of activity. The team identified that the temperature in one wing was too high for the medical well-being of their residents and made the decision as a group during the morning Standup Meeting. Within minutes, people self-organized to provide a pleasant alternative to the overheated area of the building for the patients in the affected wing. Soon the residents were seated comfortably in the dining room, offered beverages and provided with activities to engage them for the morning. Being a part of this particular morning left me with a powerful experience of Ownership, a core value for us at Ensign.

In practice, ownership takes many forms, reflecting the composition of the people who form those teams. As I reflected on why this team seemed so special, I realized that while their location set them apart in very practical terms, the quality of their interactions were definitively harmonious, often uplifting and consistently grounded in sound clinical and operational practice. These lovely people had figured out how to keep the fire lit and love one another through the usual travails of long-term care. I was struck by the balance of utter focus and levity during the morning meetings. This created the critical element of mutual understanding for each patient’s current medical and functional status for a better quality of patient care.

I was particularly struck by the level of individualized attention to ensure that each patient was situated well and individual or family needs were considered. The objective aspects of patient care were navigated skillfully while the personal needs of each patient were also thoroughly respected.

Over the course of a few days, there were many opportunities to get to know this team, and I found myself pondering how to describe what I was experiencing. There were eight factors that seemed to play a part in this team’s capacity to work so well together.

  • Relationships — These folks had healthy working relationships. They worked out their differences, held each other accountable and genuinely enjoyed working together. They even went to the movies together after work.
  • Finances — While any facility has opportunities for improvement, and the external market factors play a role in that, the basic metrics were in place and well- Census was above average and key metrics were in good shape.
  • Calm — There was a quality of calm. While the challenges were quite real, with case mix index, productivity and/or admissions, overall, this was not an anxious group. If tension arose in an interaction, there was a tendency to deal with it directly or let it go altogether. Trust played a huge role in this.
  • Creativity — On more than one occasion, I heard the IDT team generate multiple solutions to various patient issues, and then choose one, together, to solve it. This was most notable when a vociferous member of the residential community requested space that was scarcely available, yet a solution was provided that worked for everyone involved.
  • Health — If we’re looking at the collective level of function of a team or teams, the overall health of the Interdisciplinary team partners and the therapy department partners was remarkable. While any one of these folks would admit that their work could be challenging, on the whole, they knew that they had each other’s backs and found ways to express that easily and frequently, often in simple ways. For example, they’d share food to create a group lunch, or bring tea or coffee for all to enjoy; express words of appreciation and silent exchanges of support; clean a certain mug for a friend; or draw a picture for each other when documentation was completed.
  • Intelligence — In and of itself, the sheer experience of simplicity was part of the intelligence of the way that ownership was enacted within Park Manor. I felt as if the common courtesy and willingness that these partners extended for their work and for each other possessed a quality of coherence that was palpable and easily observed in patient/therapist interactions.
  • Flow — The innate intelligence of the team could be seen in the way they addressed the temperature in the south wing being too high on the morning that I visited the building. There was calm but decisive decision-making happening with a seamless flow of activity and an unflustered interdisciplinary team swiftly evacuating two dozen residents to a cooler area. That’s flow.
  • Generosity — The consistency of the integrity, accountability and genuinely generous performance that these leaders modeled, coupled with their mutual respect for each other as functional counterparts created a very visible absence. There was no silo. Each leader understood and acted as though they comprised the whole well-being of the facility. They fully supported each other within the scope of their roles, and they took every action possible to ensure continual success to whatever degree they could actuate, one day at a time.

This generosity was the spirit of ownership. It was so seamlessly implicit in the functional performance of this team that I almost missed it. The word “ownership” in our secular culture has come to mean possession, yet here, the opposite is true. When we consciously choose to open up and own more, to bring awareness and act as if our collective results are actually our own, new possibilities open up. New perspective. New hope.

By Willow Dea, Leadership Development

Evaluation vs Treatment Notes

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By Lori O’Hara, MA, CCC-SLP – Therapy Resource, ADR/Appeals/Clinical Review

CMS doesn’t define a lot of requirements for what needs to be in a daily note, understanding that it’s what happens during the session that drives the content. But one of the places where they do define a requirement is on the day of the evaluation. Because evaluation minutes don’t count towards the calculation of a RUG score, but treatment minutes do count, they want to be able to see easily that those things were different when they occur on the same day. That means a narrative entry is always required when treatment occurs on the day of the evaluation.

What needs to be in the note? Content that describes how activity billed to the treatment codes was clearly not activity that should have been billed to the evaluation code. So the content in the therapy CPT boxes should describe skilled activity associated with the specific treatment code being billed.

Content that is providing detail on the evaluation findings, interpreting scores or risks associated with testing performance with the patient or family, or describing goal setting is evaluation related. So this cannot be billed towards a therapy code and should not be documented in therapy CPT boxes.

Education about the patient’s conditions or limitations, trialing devices or attempting environmental adaptations, and specific therapeutic interventions are treatment related and should be billed to and recorded as their corresponding CPT codes. Content should be detailed enough that it’s evident to anyone reading that those activities were clearly distinct from the evaluation activity.

Reviewers are starting to look for this – managed care organizations too! So, protect your minutes on your evaluation day content that is just as amazing as the services you provide.

Our Newest SPARC Award Winner!

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Congratulations to our newest SPARC Award Winner, Hannah Ruth Downing, SLP Student at Sacramento State University, Grad Date 5/19/2019

Read her Winning Essay Here:

“What do you want to be when you grow up?” is the question I was continually asked as a child. Being raised in the Filipino culture, one is expected to become a nurse, doctor, or have almost any job relating to the medical field, but this did not seem like something I wanted to do. From a young age I enjoyed the idea of becoming a teacher. As I grew older I tutored elementary students at a local middle school, and there my ardor for helping kids increased. The thought of becoming a teacher continued to linger in my mind, but the voices of others encouraged me to choose otherwise. Going into college, I chose to pursue occupational therapy due to the fact that it was in the medical field, and I could specialize in pediatrics. However, I quickly realized that occupational therapy was not the career choice that suited me best. I then stumbled upon speech pathology. This career field had both aspects that I was looking for, teaching kids while being in the medical field. The classes I began to take and the volunteer work that coincided, sparked my interest.

Having finished my first two semesters in the communication sciences and disorders major, I was taught the basics such as the anatomy that is used for speech and swallow, language disorders in children, how effects to the brain can disrupt the language process, and various other topics. I soaked up the majority of the information given to me by my professors and I enjoyed learning everything, but by putting the knowledge I had obtained, over the two semesters into practice, I was enabled to truly comprehend the things that were taught to me.

During the first two years in college I was a childcare attendant at California Fitness. I was able to observe and interact with typically developing children, and with the knowledge I held at the time, I was able to distinguish kids that incorrectly produce sounds that were typical for their age and others who could not. This was the first encounter where I was able to practice what I had learned. This aroused my desire to learn more in order to implement the information I was attaining, so I decided that I needed more exposure to the field that I was working towards. During my third year, I got hired at Genesis Behavior Center as a behavioral therapist working with children with autism. This job has allowed me to apply a lot of the information about autism that was taught by my professors because a lot of the clients on an SLPs case load are on the spectrum. The most impactful thing that I have obtained, as well as what has driven me to learn more from being a behavioral therapist, is the struggle of communication that someone with autism faces. As a behavioral therapist, I have to train my clients how to communicate their emotions in the most effective way. In training a child with autism, how to do this can be complicated and it can take weeks, months, or even years to accomplish. However, when the child finally understands that when they are mad the inappropriate thing to do is throw a chair across the room, and instead they can simply state that they are mad and take some deep breaths to calm down, this is the moment that brings me so much joy. I have learned that communication is extremely important, and when communication is hindered, by a developmental disorder like autism or aphasia from a stroke, it can cause a copious amount of stress on the person with a disability as well as the people around them.

Working at Genesis reaffirmed my love for working with children, and although my passion for helping kids had increased, I still needed to gain experience by working with adults. I began getting involved with several organizations such as Elk Grove Adult Community Training (EGACT) and Training Toward Self Reliance (TTSR) where they both work with adults with developmental disabilities such as Down’s Syndrome, cerebral palsy, or autism, Head Trauma Support Program (HTSP) where they work with clients who have had a traumatic brain injury, and lastly stroke support group. Volunteering at these organizations was an immense revelation that left me heartbroken. There were two paramount concepts that I gained from my experience, first was the fact that kids grow up. I knew that kids obviously grow up, but I forgot that even though they get older their disabilities do not disappear. There is so much focus on early intervention, which is not a bad thing, but people often forget that adults with disabilities still need guidance and assistance. I was so happy to see day centers like EGACT and TTSR assist adults with disabilities go to and interact with each other as well as guide them so that they can continue to be a part of society regardless of their condition.

The second concept was the fact that before the patients had a stroke or TBI, they lived functionally. When going to HTSP meetings I noticed that a lot of the clients had tattoos. In order to get those tattoos they had to have the ability to make the executive decision to get something that would be permanently on their body, however, when you see them now they cannot even form a sentence, let alone a word. I realized that a lot people that encounter patients with TBIs or strokes were treating them as a person with a disability, and not just as a person. We often forget they used to have normal lives and were capable of accomplishing daily tasks themselves, and that they are just working to get back to what they remember as normal. One of the patients at the stroke support group meeting stated that, “It was like tracing out your ABC on the wide rule paper like you were in kindergarten again, but in kindergarten I probably did it better. I have to learn everything over like I’m a child.” This statement impacted the way I saw patients that had gone through a stroke or TBI. It made me realize how frustrating ever day must be for them, and going to school to potentially become someone that could help them try to get back to living functionally really encouraged me. Even though my passion is working with children, volunteering at these organizations has not only opened my eyes to many misunderstood concepts, but it has also driven me to want to understand and learn more about working with adults.

Overall, the classes I have taken for communication sciences and disorders, have aided me when I am volunteering. It allowed me to understand the absence of pragmatic skills in kids with autism, and the many different aphasias one can experience after enduring a stroke. I can easily see and pinpoint things I am learning in class to what I experience as I work and volunteer. I am aware that I still have so much to learn because even though with all the knowledge I have obtained, I continuously ask myself questions when I encounter certain situations. These questions can only be answered as I learn more, which has driven me to want to continue in my education. This scholarship money will allow me to further this desire of learning in order to gain more experience, enabling me to treat my future clients with the utmost excellent care they deserve.

Stop Managing Incontinence. Start Treating It! Here’s How…

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By Jon Anderson, Senior Therapy Resource – Texas

If you or a loved one has bladder control issues, you’re not alone. Millions of people in senior living facilities are in the same situation. In fact, more than 70 percent of long-term care residents are not in complete control of their urinary bladder function.

Bladder control problems, such as overactive bladder (OAB), are not a normal part of aging. OAB is not something one has to accept. OAB can limit social life, making it harder to share meals, play cards and stay active in the community. There are also serious health risks associated with this condition, from urinary tract infections and poor sleep to skin problems and falls. OAB is a treatable condition and can be treated in the long-term care facility by a physical therapist.

What Is OAB? OAB is a common condition that prevents you from controlling when and how much you urinate. People living with OAB may experience any of the following:

  • Urgency — the sudden sensation of needing to use the bathroom
  • Frequency — using the bathroom more than eight times per day
  • Urge incontinence — unexpected small or large leaks

Physical therapy can treat OAB through utilization of Medtronic NURO system. How does this therapy work? Medtronic Bladder Control Therapy delivered by Medtronic NURO system restores bladder function by stimulating the tibial nerve through an acupuncture-like needle placed near the ankle.

The therapy is delivered during a 30-minute session, once a week for 12 weeks, by a licensed physical therapist and is covered by Medicare and most insurance providers. This therapy is proven to significantly improve the symptoms of OAB, reducing urgency, frequency and daily urge incontinence episodes. Several recent studies have shown the therapy to decrease OAB type symptoms by 40 percent. At Ensign Affiliates, we are currently piloting this therapy at Legend Oaks San Antonio West and are looking to expand the pilot in the coming months. The most common side effects of PTNM are temporary and include mild pain and skin inflammation at or near the stimulation site. Rest assured, the stimulation is gentle on the patient. It is not painful, although your patient may feel a slight tingling in their heel or the base of their foot. For full prescribing information, see professional.medtronic.com/NURO.

Six Simple Steps to Launch a Successful Heart Math Program

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By Jen Farley, Therapy Resource & DOR, Sea Cliff Health Care Center, Huntington Beach, CA

At Sea Cliff Health Care Center, the therapy team actively incorporates Heart Math techniques into daily treatments. Heart Math is a highly effective, multifaceted program that has had a positive impact on the majority of our patient population. Self-regulation is recognized as a key factor to assist in recovering from illness and improve functional performance. Listed below are the six steps used to implement the Heart Math system.

Step One: Get Trained

Contact Mary Spaeder or your local Resource to plan for a hands-on training experience. Generally, the train

Kristi Rosales, PTA, will be the team lead for the HeartMath program at Sea Cliff

ing is completed in an hour. Invite IDT members, EDs, cluster partners and marketers to a Lunch & Learn training. IDT member education highlights the benefits of Heart Math programming. Additional training provided by Dr. Timothy P. Culbert, M.D., is available for advanced certification. Sea Cliff has identified a PTA for completing the certification program and will be recognized as the team lead.

Step Two: Identify Your Target Resident Population

An effective treatment plan includes an evaluation and four to six treatment sessions, 30 to 45 minutes each, within two to four weeks. Collaborate with the resident and the family in setting up a consistent treatment schedule. Sea Cliff has incorporated the emWave Stress relief system with Heart Math techniques. Sea Cliff’s resident population has a broad scope of medical diagnosis. Participating residents have experienced a significant reduction in hypertension, pain, poor sleep, anxiety and depression.

Step Three: Establish Your Treatment Location

A quiet environment is recommended. Sea Cliff consolidated two work offices into one, and the benefit is now a quiet treatment room. Team members collaborated on room design, color and furnishings. Therapists initiated and purchased a pre-owned, low-cost high-low mat. Extra seating is available for family members to attend the treatment sessions.

Step Four: Provide Consistent Follow-Through

Follow-through is both the greatest challenge and the greatest opportunity for therapists as they work to achieve successful treatment outcomes. Scheduling treatment times in a quiet environment enhances the resident’s experience. It is important for the DOR to review the treatment goals and progress. Residents, caregivers and family members appreciate the opportunity to participate.

Step Five: Get Reimbursement

At Sea Cliff, we include billing under Therapeutic Activities or Self Care. For example, charting may include “Heart Variability training to address SOB, fatigue and low endurance to increase activity or ADL tolerance.” Therapists will want to write a specific goal. Documentation should focus on how the use of Heart Math Variability training can increase focus and decrease anxious behaviors to increase safety and participation in self-care and therapeutic activities.

Step Six: Have Fun!

Share your success stories at the Annual Therapy Meeting, the quarterly DOR Meetings and the Monthly Cluster Meetings. Other pathways to highlight this unique program include marketing events, facility tours, IDT care plan meetings and community outreach. When Therapy has fun, everyone has fun!

Making E-Stim Bulletproof

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By Lori O’Hara, MA, CCC-SLP – Therapy Resource, ADR/Appeals/Clinical Review

One of the most common reasons for denials in both the Medicare and managed care areas is removing e-stim minutes because the documentation doesn’t support a skilled service.

Reminder! No one pays the machine, so the amount of time the machine is running has nothing to do with how much time is billed. What is reimbursed are the minutes that required a skilled brain — so clearly describing the minutes when the brain was engaged is critical!

Typically, the skilled time includes: assessing and prepping the patient for treatment (including a skin check), applying the electrodes, selecting and inputting the parameters, time spent during the treatment assessing for tolerance or accommodation and making any adjustments, and the post-treatment take-down (including another skin check) and assessments.

Patients who rapidly and frequently accommodate to the current, or roll over from sensory response into a pain response, may require skilled attendance the entire duration of the delivery — but that is not common, so when it occurs it must be very well-documented.

Also remember to put billed minutes in the right place! If you’re using e-stim as an adjunct to neuromuscular re-education or therapeutic exercise, make sure you record the minutes properly. Lumping your treatment minutes into the e-stim code creates an artificially high delivery that the documentation will almost certainly not support.

And finally, the cherry on top: Conclude your narrative entry with a summary statement about the billed time for one-on-one skilled intervention, e.g., “Total number of one-on-one skilled time = 16 minutes.” This is even stronger if the run time is detailed in the description of the e-stim parameters.

Please see the Supervised Modalities POSTette on the portal for more details and examples.

Are You Uncomfortable?

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By Willow Dea, Therapy Resource

“Comfort is not the objective in a visionary company. Indeed, visionary companies install powerful mechanisms to create /dis/comfort — to obliterate complacency — and thereby stimulate change and improvement /before/ the external world demands it.” -James C. Collins

We take tremendous care to achieve our mission every day: To dignify and transform long-term care in the eyes of the world. We do that by enacting a pledge to our core values, which foster a culture of integrity and compassion for our patients and their families.

These commitments ask everything of us. They require each of us to explore a profound, and continuously evolving understanding of leadership. Every Ensign affiliate is a leader; it’s part of the agreement we made when we accepted our respective positions. As partners in this endeavor, we are offered an opportunity to be part of something much greater than ourselves. It’s in this context that I find myself wondering how to be a better partner to each of you and a better leader, especially in practical terms. What does it actually look like, as a set of behaviors and outcomes, to be a leader?

Good to Great[1] revealed the traits of great leaders, and we’ve benefited from learning from these examples. We know that taking responsibility, being humble, getting the right people on the bus, being able to ask for help and leading with passion are essential characteristics and skills for building great organizations and realizing our mission.

Yet the question of how to develop those traits remains somewhat elusive for me, even with such clear stories. In practice, this means we get to cultivate new habits and practice new behaviors. To do that, we need to get comfortable with the uncomfortable. Easier said than done, right? Where do we start? It’s been said that habits are more powerful than fear and that “life begins at the edge of your comfort zone.”

Fortunately, many people are asking similar questions, in every industry sector. Extensive research has been done to help us grapple with these central concerns and effectively answer them. Leadership Agility is based on the rigorously researched developmental framework presented in the award-winning book Leadership Agility: Five Levels of Mastery. The three dimensions of this framework are summarized below.

The Developmental Model[2]

Agility Levels

The first aspect is a description of the “leadership agility levels” that came out of the research. As managers develop, they grow through stages or levels of agility that can be clearly defined and measured. Teams and leadership cultures have the potential to evolve through parallel levels of agility. The three levels of leadership agility most relevant to the vast majority of today’s organizations are:

  • Expert: Managers who operate at this level of agility use their technical and functional expertise to make tactical organizational improvements, supervise teams, identify and solve key problems, and sell their solutions to others. Research indicates that approximately 45 percent of today’s managers operate at this level of agility.
  • Achiever: Managers who function at this level of agility use their managerial skills to set clear organizational objectives, lead strategic change, motivate and orchestrate team performance, and engage in challenging cross-boundary conversations. About 35 percent of today’s managers operate at this level of agility.
  • Catalyst: Those rare managers who have developed this level of agility are visionaries who can lead transformative change, develop high participation teams, and collaborate with others to develop creative, high-leverage solutions to tough organizational issues. About 10 percent of today’s managers operate at this agility level.

As change accelerates and the world continues to become more complex, the need increases for more Experts to become Achievers and for more Achievers to develop the capacities and skills needed to operate at the Catalyst level. In this increasingly turbulent environment, teams and leadership cultures are challenged to undergo parallel developments.

Action Arenas

As leaders develop through the levels of agility described above, their capacity for taking leadership in all three key leadership arenas expands and becomes more effective:

  • Leading organizational change
  • Improving team performance
  • Engaging in pivotal conversations

The Agility Compass: Four Types of Agility

Joiner and Joseph’s research found that agile leaders employ four types of agility, which work together to increase the effectiveness of leadership initiatives in each of the three arenas. The four types of agility are briefly summarized below:

  • Context-settingagility determines how leaders scan their environment, select key initiatives, then scope and set objectives for these initiatives
  • Stakeholderagility determines how leaders identify and understand key stakeholders, as well as their ability to create greater alignment with different stakeholder groups
  • Creativeagility determines a leader’s ability to identify the key problems an initiative needs to solve, get to the underlying issues, and develop creative solutions that work for multiple stakeholders
  • Self-leadershipagility determines how proactive leaders are in experimenting with new leadership behaviors and in learning from their experience

If your curiosity is sparked and you’d like to learn how to reach your next level, reach out to Willow Dea at WDea@EnsignServices.net to take a self-assessment. It takes about 10 minutes, and you’ll leave with a clear understanding of exactly what you can practice to become the leader you aspire to be.

Remember, “The job isn’t to catch up to the status quo; the job is to invent the status quo.” — Seth Godin

[1] Good to Great, James C. Collins, Harper Business; 1st edition (October 16, 2001)

[2] Leadership Agility, William B. Joiner and Stephen A. Josephs, Jossey-Bass; 1 edition (October 20, 2006)

 

 

A Season of Change

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By Deb Bielek, Therapy Education Resource

SUMMER!! It’s the season of the year when we celebrate sunny days, spending time at the beach or outdoors boating, camping, barbecuing with family and friends and we plan family vacations, while the kids are on break from school. For those of us who serve as therapy and nursing providers in skilled nursing, summer also carries with it another meaning. Each year and usually on the last Friday in April, the SNF Notice of Proposed Rule Making (NPRM) is made public by the Federal Government. While we often have ideas about some of the proposed regulations we may find in the NPRM, we also eagerly await the public notice so we can dive in to see if it contains any surprises. We then spend time processing, analyzing and putting together thoughtful comments for the Federal Government to consider before releasing the SNF Final Rule, which is typically published sometime in August. The Final Rule directs our next season of reimbursement and regulatory requirements.

 

The proposed rule Fiscal Year 2019 has been considered by many to be the most anticipated rule proposal since the introduction of the Medicare Prospective Payment System in 1998. The NPRM was released to the public on Friday, April 27, 2018, and introduced us to a new payment model entitled, the Patient Driven Payment Model (PDPM), which is suggested in the rule to become effective in October 2019.

CMS Administrator, Seema Verma, describes the proposed rule in this way:

“We envision all elements of CMS’ healthcare delivery system working to reward value over volume and decisively focus on patients receiving quality care from their Medicare benefits. For skilled nursing facilities, we are taking important steps through proposed payment improvements that will reduce administrative burden, and foster innovation to improve care and quality for patients.”

CMS further describes PDPM as an innovative new system for SNF payment that ties payment to patients’ conditions and care needs rather than volume of services provided. PDPM is proposed to simplify complicated paperwork requirements for performing patient assessments by significantly reducing the MDS reporting burden. The proposed new PDPM is designed to improve the incentives to treat the needs of the whole patient, instead of focusing on the volume of services the patient receives. This approach advances CMS’ efforts to build a patient-driven healthcare system beginning with innovation throughout Medicare’s payment systems.

We recognize that under the newly proposed SNF case-mix model, skilled nursing facilities which offer services tailored to individual patient conditions rather than the specific individual services provided by the SNF will become most important. You will want to think more about the outcomes you achieve when treating a patient who has had an acute neurological condition, for example. Do your patients go home more often? Do they improve more significantly? Do they stay free from readmission to the hospital longer after discharge from the SNF? If this model becomes the final rule, data such as this will be more accessible to your patients, allowing them to be more informed as they evaluate their options for post-acute care.

As an industry, we have opportunities to be the setting of choice under a value-based model, but we MUST continue our focus on providing interdisciplinary, patient-centered care, while measuring and analyzing our results, and making adjustments where needed. Standardized Tests, interdisciplinary communication, CARE & NOMS data (Section GG), evidence-based practice, reducing re-hospitalization through predictive assessments such as the LACE Tool, better discharge planning and enhanced patient engagement are all the keys to success as the Improving Medicare Post-Acute Care Transformations Act of 2014 continues to make its IMPACT through rules refinement. How will you and your program continue to be the provider of choice in the Healthcare Communities where you operate this summer and all year long—Best in the World!

Compliance Corner

Your Friendly Neighborhood Compliance Partner

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By Billye J. Lee, PT, GCS, RAC-CT, Therapy Compliance Partner — Keystone

My family recently went to see the new “Avengers” movie, being Marvel comic fans and all. Action flicks are a rare treat for our busy family, and the latest in the series did not disappoint. In one intense scene where young Spiderman decides he will stay and fight alongside his team, he states, “You can’t be a friendly neighborhood Spiderman if there’s no neighborhood!” Now, I’m not saying Compliance is nearly as cool as Spiderman, but I would agree with his premise: We are nothing without those we serve.

This statement is so true throughout our Ensign family and is a common thread within our CAPLICO culture. Without our employees, there would be no “who,” no bus to drive. Without our residents, there would be no purpose or “what,” no mission. And for Compliance, without our facilities and markets, there would be no team, no momentum.

As much as I would love to get high-fives, slow clapping and gasps of relief when I enter a building (Yay, Spiderman is here!), I know in reality, Compliance visits are not always joyous events. However, we would love to challenge that perception! Yes, it can be uncomfortable “turning over rocks and looking at the squiggly things,” but identifying our risks keeps us tethered to our process toward greatness. You see, we are on the same team! We love our markets, buildings, resources and staff members. We want to help you achieve your goals and add value to your systems. Being sustainable in a competitive industry means we have more time together to do what we are most passionate about.

Although Audits, IRO support and Investigations are critical to our role, Compliance can also provide education, in-services, clarification, observe meetings, answers to questions, and assistance with goals — dare I say, it can be the web that pulls it all together. As service providers, please reach out to your Compliance Partners if you need us or have questions. Even if you don’t have questions, but would like more information about a Compliance topic, please don’t hesitate to contact us. If you’re not sure who your Compliance Partners are, you can locate us on the Portal, under Compliance, at the very bottom of the page, at “Compliance Contacts.”

-“Greatness is not a matter of circumstance. Greatness is a matter of conscious choice and discipline.” — Jim Collins ..OR, “Remember, with great power, comes great responsibility.” — Uncle Ben