Effective: May 26, 2026
Compliance Deadline: May 26, 2028

What’s Changing

The federal government has finalized a rule requiring standardized electronic submission of “claims attachments.” The clinical documentation that supports billing (nursing notes, doctor’s notes, therapy evals, daily notes, progress notes, discharge summaries, etc.).

• Fax, mail, and manual uploads will be phased out
• Documentation must be sent using standard electronic formats and transactions

Why This Matters to Us

This rule directly impacts how documentation supports claims and how quickly facilities get paid.

• Documentation will be requested and transmitted electronically
• Payers will review information faster and more consistently
• Incomplete or delayed documentation will be more visible and more likely to be denied

 

To successfully comply with these changes, there are four key areas we need to focus on:

1. Documentation Timeliness

• Payers can request documentation electronically and expect a rapid response
• Delays in documentation equal billing delays or denials

Focus Area:

Assure you are reviewing documentation timeliness expectations (i.e., documentation completed same day or within defined facility timelines).

 

2. Documentation Quality

Standardized formats make it easier for payers to scrutinize documentation more closely:

• • Identify missing elements
  • Apply consistent audits

Focus Areas:

• Medical necessity is clearly documented across the medical record (nursing notes, doctor’s notes, MDS, therapy notes)
• Functional outcomes are consistently documented

 

3. Electronic Signatures

• All documentation must include secure, authenticated e-signatures

Focus Areas:

• Timely signatures and co-signatures
• No backlog of unsigned documentation

 

4. Workflow Discipline

Manual “we’ll send it later” processes will no longer work.

Focus Areas:

• Daily documentation expectations are set and understood by the IDT
• Clear ownership for completion, corrections, and timeline
• Rapid response to documentation requests – the team knows their piece of the puzzle and the timeframe in which it is expected to be done. Members of the team have a designated backup champion for when they are not at work.

Your Power Points

1. Fax Is Going Away

• By 2028, faxed documentation will not meet federal requirements
• Facilities must support fully electronic workflows

2. System Readiness Is Essential

Facilities must ensure their systems can:

• Generate compliant documentation formats
• Integrate with therapy and billing vendors
• Support electronic attachment workflows

3. Vendor Alignment Is Critical

This rule requires coordination between:

• Therapy
• Facility EMR
• Billing partner
• Clearinghouse

A gap in any area can delay claims.

4. Faster Requests = Faster Expectations

• Payers can request documentation electronically
• Facilities must be ready to respond quickly

Delays in documentation completion can and will directly impact reimbursement.

 

Recommended Workflow Review Areas:

• Delayed or incomplete documentation – Run audits to ensure documentation timeliness.
• Unsigned or improperly signed notes – Assure a good process is in place so that documentation is signed as required.
• Lack of system integration between vendors – Integration between therapy and nursing EMRs can assure more timely access to documentation. If you are already integrated, ensure your integration is operating as intended. If you are discussing integration, reach out to your Regional Director if you have any questions.
• Inconsistent documentation practices across buildings – If you are a multi-site organization, ensure workflow consistencies across your buildings. This aligns expectations and creates an easier audit process.

How HTS is Supporting You

HTS is actively evaluating system readiness and integration requirements as both PCC and Matrix have or are currently undergoing integration modernization.

HTS maintains a dedicated integration lead who drives alignment between systems and rapidly identifies and resolves integration issues between the nursing EMR and therapy EMR.

HTS has already done the following:

• Reinforced documentation timeliness expectations with teams
• Audited for signature compliance
• Provided routine standardized documentation quality assurances across buildings

 

Next Step for HTS Partner Facilities:

• Engage your EMR, billing vendor, and clearinghouse on readiness
• Assess current reliance on fax/manual processes
• Partner with your HTS Regional Director to streamline workflows

 

This is not just a billing change, it is a documentation, workflow, and technology shift that will impact reimbursement speed, compliance, and audit risk. Organizations that prepare early will see faster payments and fewer denials.

Written By:

Sheena Mattingly, M.S., CCC-SLP, RAC-CT

Executive Vice President of Quality & Compliance

Healthcare Therapy Services, Inc.

 

 

The Fall 2025 Semiannual Report to Congress from the Office of Inspector General (OIG) offers more than a summary of enforcement activity; it provides a window into how healthcare oversight is evolving. While the report spans the full healthcare landscape, its themes carry meaningful implications for skilled nursing facilities (SNFs), particularly as regulators continue to scrutinize quality, documentation, and data integrity.

A Growing Enforcement Footprint

At a high level, the OIG reported approximately $19 billion in total monetary impact for fiscal year 2025, reflecting recoveries, cost savings, and identified overpayments. This reinforces both the scale and seriousness of federal oversight.

Just as important as the dollar amount is how enforcement is being carried out. The report highlights a continued shift toward:

• Data analytics to identify outliers
• Cross-agency collaboration
• Proactive identification of risk areas

For SNFs, this means oversight is no longer solely reactive. It is increasingly predictive and data-driven.

 

Quality of Care Is No Longer Just a Survey Issue

The report and related OIG enforcement activity continue to highlight persistent concerns in nursing homes, including:

• Staffing shortages
• Infection control deficiencies
• Failures to meet basic care standards
• Gaps in employee background checks

While these issues are familiar, the implications are evolving. When these deficiencies result in harm or when providers bill for services that do not meet required standards, they may escalate beyond survey citations into enforcement actions.

Key Shift:

• Quality Concerns → Regulatory Citations
• Quality Failures → Potential Fraud & Enforcement Exposure

This reframes quality as not just a clinical priority, but a compliance and financial risk.

 

 

Data Accuracy & Fall Reporting Concerns

A separate OIG report released during the same period found that 43% of falls with major injury were not reported in required resident assessments. While this finding is not from the Semiannual Report itself, it reflects a broader concern about the reliability of reported data.

For SNFs, this raises important questions about:

• Accuracy of Minimum Data Set (MDS) reporting
• Alignment between internal incident logs and submitted data
• Whether reported outcomes reflect actual clinical events

Facilities with unusually low rates of adverse events may not appear high-performing. Instead, they may instead appear inconsistent or inaccurate when compared to other data sources.

 

Documentation & Payment Integrity Expectations

Across healthcare programs, the OIG continues to identify improper payments tied to insufficient or unsupported documentation. While much of the focus is on Medicare Advantage, the expectation applies broadly.

For SNFs, this reinforces a fundamental principle:

• If it is not documented, it is not defensible

Areas that warrant particular attention include:

• Skilled need justification
• Therapy services and intensity
• PDPM drivers and coding accuracy
• Hospitalization and rehospitalization documentation

As analytics become more advanced, billing patterns that deviate from peers or that lack supporting documentation are more likely to be flagged.

 

Workforce Compliance Is a Risk Area

The OIG’s identification of failures in background checks and registry screenings signals that workforce compliance is under increasing scrutiny.

This elevates HR processes into the compliance spotlight. SNFs should ensure:

• Background checks are completed prior to hire
• Abuse and neglect registries are consistently queried
• Documentation is complete and auditable

Inconsistent hiring practices are no longer just operational gaps; they are potential compliance vulnerabilities.

 

Growth Attracts Scrutiny

The report also highlights areas of rapid spending growth across healthcare, reinforcing a consistent OIG pattern: high-growth areas attract attention.

While not SNF-specific, the implication is clear. Providers should closely monitor trends such as:

• Therapy utilization patterns
• Length of stay variations
• High-acuity coding categories
• New or expanding service lines

Any significant deviation from industry norms should be understood, explainable, and documented.

 

The Bigger Shift: From Reactive to Predictive Oversight

Taken together, the Fall 2025 report reflects a broader transformation in how oversight is conducted.

Then:	Now:
Surveys	Data Analytics
Complaints	Pattern Recognition
Retrospective Audits	Outlier Identification

 

Facilities may face scrutiny not because of a specific event, but because their data suggests risk.

 

 

What SNF Leaders Should Do Now

To align with this evolving environment, providers should focus on:

• Validating Data Accuracy
  • Ensure MDS, incident reporting, and documentation align
• Strengthening Internal Audits
  • Focus on falls, therapy utilization, and coding
• Aligning Documentation with Billing
  • Every billed service should be clearly supported
• Auditing HR Compliance
  • Apply the same rigor as clinical reviews
• Monitoring Internal KPIs
  • Identify and investigate outliers early

 

Your Power Points

The Office of Inspector General is not just identifying problems; it is signaling how providers will be evaluated moving forward.

For SNFs, success will depend on the ability to ensure that all of the items below are consistently aligned and defensible.

Care is Delivered → Care is Documented → Care is Reported → Care is Billed  

Today, the question isn’t simply whether care occurred. It’s whether you can prove it in a way that stands up to scrutiny.

 

 

Written By:

Sheena Mattingly, M.S. CCC-SLP, RAC-CT  |  Executive Vice President of Quality & Compliance

About Sheena:

Sheena Mattingly is a Speech Language Pathologist and the Executive Vice President of Quality and Compliance for Healthcare Therapy Services, Inc. Sheena has a passion for advocacy and is the Chair of the Advion Compliance Committee, addressing critical and emerging topics including: policy development, corporate compliance strategy, artificial intelligence in healthcare, and denials management. She is active in her advocacy role for post-acute care providers by meeting with legislators on Capitol Hill to discuss issues that directly impact providers, clinicians, and patient care. Sheena serves as a member of the Advion Data Compliance Committee, which allows her to present data findings to CMS that ultimately shape fair and sustainable payment methods.

 

It’s Spring! The sun is out and the days are longer, making it the perfect time to move a little more. After months of winter, many of us feel slower or low on energy. Small daily habits can help you feel stronger, steadier, and more lively.

 

5 Energy Boost Tips

 

1. Move Daily: Any movement, such as walking, stretching, or household chores, can help your body feel more awake and energized. Try to move a little each day.

 

2. Pace Yourself: Break chores or daily tasks into small steps and take short rests in between. This helps keep your energy steady and prevents fatigue.

 

3. Fuel Your Body: Choose protein-rich snacks like yogurt, cheese, or nuts, and sip water throughout the day. Staying nourished and hydrated helps keep your energy steady.

 

4. Get Sunlight: Spend a few minutes outside or by a sunny window. Sunlight helps wake up your body, lift your mood, and support energy for the day.

 

5. Stay Social: Spend time with friends, call a family member, or join a group activity. Connecting with others can naturally lift your energy and lift your spirits.

 

How Therapy Can Help

Talk with your doctor to see if therapy could help you stay active and confident. Physical therapy improves strength and balance. Occupational therapy makes daily tasks easier and safer. Speech therapy supports memory and communication. Together, therapy can help you enjoy your favorite activities with more energy.

Change is underway for nursing facility Medicaid reimbursement in Indiana, and while some updates take effect sooner than others, all of them are worth providers’ attention now.

An official announcement has been released outlining changes to Nursing Facility Medicaid rates effective State Fiscal Year (SFY) 2027, along with continued planning for the future implementation of the Patient Driven Payment Model (PDPM). The full announcement is posted on the Myers and Stauffer website.

 

What’s Changing for SFY 2027 Medicaid Rates

For SFY 2027, Indiana will adjust the Minimum Data Set (MDS) reporting period used to calculate Medicaid Case Mix Indexes (CMIs). Instead of relying on more recent assessments, Medicaid CMIs for SFY 2027 will be based on MDS data reported during SFY 2026. Specifically, assessments from September 1, 2024, through August 31, 2025, will be used, with data weighted by Medicaid days.

The resulting Medicaid CMI will be applied to both semi-annual rate periods in SFY 2027. Rates effective July 1, 2026, will reflect this calculated CMI, including any revisions resulting from MDS reviews for that reporting period. That same CMI will also apply to the January 1, 2027, rate period, again incorporating any changes identified through the review process.

 

PDPM: Not Here Yet, But Getting Closer

While Medicaid rate changes are imminent, PDPM implementation remains a future event. Indiana continues to target SFY 2028, effective July 1, 2027, for adopting PDPM for nursing facility rate setting. Although discussions are still ongoing, the announcement provides insight into the structure Indiana plans to use when PDPM is implemented.

Indiana’s PDPM approach will rely on the PDPM Nursing Component and will use Medicare PDPM Nursing Component CMI weights that were in effect on October 1, 2023. The low-needs resident classification will be eliminated under PDPM, and Interim Payment Assessments (IPAs) will be considered valid for resident classification and assignment of days. These design choices signal a meaningful shift from the current case-mix methodology and underscore the importance of accurate and timely MDS reporting.

 

Preliminary PDPM Reports: A Practice Run with Purpose

Providers have already begun receiving Preliminary PDPM Time-Weighted CMI Resident Roster Reports. While these reports are not being used for reimbursement at this time, they serve as an early look at how resident classification and case mix may appear under PDPM.

The first set of preliminary reports, covering Q4 2025, was posted on December 10, 2025, through the Indiana MDS Web Portal. Providers are encouraged to review these reports carefully, paying close attention to assessment sequencing, submission accuracy, classification logic, and coding. Identifying and correcting issues now will help facilities avoid complications once PDPM becomes operational.

 

Your Power Points

Although PDPM reimbursement is still on the horizon, the direction is clear. MDS accuracy today will directly influence Medicaid rates tomorrow. Facilities that actively monitor preliminary reports, address data issues, and stay informed as guidance evolves will be better positioned for a smoother transition.

Additional communication is expected as PDPM implementation approaches, and providers should continue monitoring updates from Myers and Stauffer.

 

Questions or Need Clarification?

Providers with questions regarding SFY 2027 Medicaid rates or PDPM reporting should contact Myers and Stauffer directly at 317-816-4122 or via email at INHelpDesk@mslc.com or LTCdept@mslc.com. The full announcement is available on the Myers and Stauffer website for reference.

 

Written By: Sheena Mattingly, EVP of Quality & Compliance

As winter comes to an end, you may notice that your body does not feel quite like it used to. Your joints may feel stiff, your muscles might seem weaker, or you may feel a little unsteady walking across the room. You are not imagining it. Many adults notice these changes after spending more time indoors during the winter months.

When we move less, even for a short time, our bodies can start to change. Muscles that are not used as often can lose strength faster than expected. Joints may feel stiff when they are not moved regularly. Balance can also be affected as the small muscles and reflexes that help keep you steady become weaker. Paying attention to these changes early can help prevent bigger problems later on.

 

You may benefit from therapy if you have noticed any of the following:

• Increased Stiffness in Your Joints
• Walking Slowly
• New Aches or Soreness
• Poor Balance and Falls
• Trouble Climbing Stairs
• Needing More Effort to Get Up From a Chair
• Feeling More Tired During Everyday Activities
• Difficulty Getting Back to Activities You Enjoy

 

How Therapy Can Help:

Physical and occupational therapy focus on helping you move better. This can mean walking with more confidence, getting dressed more easily, or safely returning to the activities that matter most to you.

If any of these signs sound familiar, talk with your doctor about whether therapy may be right for you. Our therapy team is here to help you feel stronger, move more comfortably, and stay independent.