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SLP Case-Mix Group: What We’ve Learned

Accurate coding for the SLP Component under the PDPM reimbursement methodology has been an area of opportunity across the industry. HTS has uniquely positioned itself with a team of seasoned therapists and nurses to analyze data and trends to optimize systems and processes to assure a smooth transition into PDPM. Now that we have three months of PDPM under our belt, here is what we have learned:

  • A tool to communicate SLP evaluation findings to the IDT will streamline the process and optimize IDT collaboration. Our MDS coordinators have enough on their plates. Let’s make it as easy as possible to present them with information so they can make the best coding decisions. HTS has created a tool for this, “HTS IMA SLP Component Communication Tool.” This tool is completed by the SLP and/or OT to provide information regarding sections B, C, I, and K related to the SLP therapy PDPM component. The tool is also equipped with a coding reference to assure that therapists are familiar with the RAI language and coding instructions.
  • Best practices when administering the BIMS is an area of opportunity. HTS recommends reviewing interview guidelines from the RAI, coding tips, and BIMS basics. Use HTS’ “Cognitive Assessment Quick Reference” for a guide to optimize practices in these areas. Also, remember the BIMS is a brief test and is not sensitive enough to capture some cognitive deficits such as executive functioning impairments. Even if a patient is “cognitively intact” (BIMS score of 13, 14, or 15), they still may benefit for cognitive-communicative therapy. The SLP will have formal testing to identify these areas of deficit and create short term goals associated with these areas.
  • If a patient scores in the SA case mix group indicating there are no items coded for the SLP component, the patient can still qualify and benefit from therapy. As mentioned in #2, the formal testing selections by a SLP will be more sensitive to cognitive impairment and therefore capture deficits more brief tests will not. However, if a patient is coded as “SA” and would benefit from speech-language therapy, HTS recommends going over the patient record to assure coding accurately reflects the patient’s medical complexities. Often times aphasia in section I4300 of the MDS may be a coding opportunity but also may require querying the physician. Additionally, section K coding best practices could also result in a more accurate SLP case-mix group.
  • Section K coding and optimization requires IDT collaboration. 2017 CMS data analytics revealed that section K coding was also an area of opportunity. In the past many have relied solely on the dietary department for section K coding. We’ve learned the SLP observations are also an important factor when coding section K accurately. For this reason, HTS created a “Quick Reference Optimize Coding in Section K” and “RAI Instructions for Completion of Section K.” Additionally, a webinar is available on the partner portal, “PDPM: SLP Component and Accurate Reporting of SLP Comorbidities.”

As we continue to navigate new waters under the PDPM methodology, we have adapted and modified our systems and processes to assure patient-centered care is at the forefront and best practices are in place. Accurate SLP component coding allows us the opportunity to more accurately depict the patient’s medical status and individualized needs. HTS will continue to provide the resources and tools to achieve IDT collaboration for the best patient outcomes possible so together we can drive quality improvement.

Written By: Sheena Mattingly, M.S., CCC-SLP, RAC-CT, Director of Clinical Outcomes

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PDPM Numbers After a Month: Looking Good

Article by James M. Berklan, www.mcknights.com

Journalists are supposed to be “words” men and women, but to be honest, I love a good set of numbers as much as anything. Especially when they’re tied to a pertinent analysis.

That’s why I find this period of transition with the Patient Driven Payment Model intoxicating. There’s mystery (Will providers fare well under the drastic overhaul?), cunning (How might providers get the best bang for their buck?) and suspense (What will regulators yank back if they don’t like what they’re seeing?).

And numbers. Lots and lots of numbers.

Wednesday I got a chance to talk initial PDPM numbers with three of the biggest LTC numbers crunchers around, Marc Zimmet, Vince Fedele and Steven Littlehale. We talked about Zimmet Healthcare Services Group’s initial PDPM reimbursement analysis of October Medicare claims.

The overall impression coming out of it? You’re going to be alright, providers. Just as many had predicted, those who did their homework — and vow to keep getting better — should be just fine.

In fact, as colleague Danielle Brown writes in today’s top Daily Update news item, many providers who paid attention in their PDPM educational classes are making, on average, more than $50 more per patient day then they would have under the old RUGs-IV system. When adjusted for one-time exceptions, it’s about half that, but it’s still a big positive. In addition, Zimmet estimates that providers can gain another $40 per patient day more once they get better at coding and, well, simply remembering to claim what they have coming.

While OT and PT therapy pay rates won’t necessarily budge much, better can be had in speech language therapy, nursing and non-therapy ancillary services, Zimmet explained.

A big caveat here: The analysts were clear that theirs was not a random sample and should not be taken as an ironclad predictive argument. The sample included a lot of East Coast clients, and they tended to be on the larger size, but it was still significant and close to what others should be finding.

The biggest worry isn’t so much what PDPM will do to providers’ bottom lines, but, much as I predicted a few weeks ago after talking to a long time marketplace exec: What the Centers for Medicare & Medicaid Services will do to the flow of cash when it eventually recalibrates pay rates. Because we can assume with these kinds of cheery numbers Uncle Sam will want to get back what he feels is rightly his.

Zimmet predicted with “95% confidence” that a rate readjustment will be coming, eventually. Providers will know in “less than a quarter” how finances will shake out, but CMS will likely take about six months before it makes any pronouncements about rate readjustments.

Make no mistake: This is good. It means you’re not getting riffed right now, wondering how to make ends meet. The CMS policy is not going to be budget neutral — but in a good way.

And the best thing of all is, you can do even better at it once you get better at coding and stop leaving money on the table.

Click here to continue reading this blog.

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Power Through PDPM Workshop Series

Exclusive PDPM Training For HTS Partners

We are committed to supporting our partners by offering exclusive PDPM webinar and live trainings in critical areas to foster success as we “Power through PDPM.”

Moving From RUG-IV to PDPM:  The Transitional IPA

Wednesday, September 25, 10:00 a.m. – 11:00 a.m.

Join us for the 1st High Impact PDPM Workshop where we will review how to successfully navigate the upcoming transition from RUG-IV to PDPM. This webinar will focus on completion of the required transitional Interim Payment Assessment (IPA) for current Medicare Part A beneficiaries including gathering quality assessment data and considerations for ARD scheduling.

Presented by: Eleisha Wilkes, RN, RAC-CT

 

PDPM Billing Processes

Wednesday, October 23, 10:00 a.m. – 11:00 a.m.

The importance of billing accuracy becomes more important than ever under the PDPM (Patient-Driven Payment Model) effective October 1, 2019. This session will focus on tools and strategies to establish a robust Triple Check process that providers cannot afford to overlook.

Presented by: Stacy Baker, OTR/L, CHC, RAC-CT

 

Please contact us to register. Not a partner? Contact us to learn how we’re providing even more value to our partners.

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The Key to Successful PDPM Transition Navigation

The transition to PDPM will be on October 1, 2019 resulting in a “hard stop” of RUG-IV on September 30, 2019. Strategies for a successful transition include:

  • Development of a plan for data collection for IPA look-back periods which may creep back into September dates of service.
  • Completion of a triple check process to assure COTs are accurate and completed (missed COT will be provider liable).
  • Assuring no principal diagnoses map to “return to provider”.
  • Collection of section GG interim performance data.
  • Completion of resident interviews on or before the transitional IPA ARD.
  • Optimization of processes to code diagnoses for Nursing, NTA, and SLP components accurately.

A transitional IPA will be required for each Medicare A resident present in the facility on October 1, 2019. Transitional IPAs are not to be confused with an IPA. See below for key differences:

Click here for the Variable Per Diem Adjustment Factor Fact Sheet.

 

Transition to PDPM Example

Admission Date: 9/22/19  |  5 Day ARD: 9/29/19  |  Transitional IPA ARD: 10/4/19

Source: McGill J., (Producer). (2019). Strategies for PDPM transition and IPAs [Video Webinar].
Retrieved from www.aanac.org

  • RUG-IV will be used for payment for admission of 9/22 through 9/30.
  • Payment for the transitional IPA begins 10/1 and continues through the end of the Medicare stay unless another IPA is done.
  • The Transitional IPA ARD window is October 1-7. The provider may select any of these 7 days.
  • For this example, the transitional IPA will be 10/4.
  • The variable per diem begins 10/1.
  • The NTA is adjusted by 3.0 for Oct 1-3.
  • PT/OT component will not decrease by 2% until Oct 21.

Successful transition to PDPM will undoubtedly involve optimization of efficiency in providing care and improving patient outcomes. It’s never too late to reassess and tweak your facility’s operational strategies to get ready for the transition. Don’t know where to start or stuck on a process change solution? Contact your HTS Regional Director or the HTS Director of Clinical Outcomes today!

 

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PDPM: What Hospitals Need to Know

1. Start Date: October 1, 2019

2. Applies only to traditional Medicare Part A Skilled Nursing Patients

3. PDPM is a site-neutral reimbursement structure for post-acute care.

4. May impact SNF episodic spending

5. May create opportunities for SNF to increase their clinical scope to accept higher acuity patients

6. Increase of information needed from the hospitals transfer documentation to justify all active conditions:

  • History
  • Physical
  • Medication List
  • Labs
  • Therapy progress notes
  • Chest X-ray
  • Immunizations

Additional requested information under PDPM

  • ICD.10 codes with specificity
  • All active diagnoses
  • Post-Operative Reports
  • Any physician consults

7. PDPM should NOT affect the timeliness in which patients are accepted by Skilled Nursing Facilities

8. PDPM should not drastically reduce the amount of therapies provided or weekend availability

9. This is the largest change to SNF reimbursement in 20 years

10. There is opportunity to improve processes and care collaboration between hospitals and SNFs for optimal success under PDPM

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CMS Finalizes $851M Pay Bump for Nursing Homes, Rolls Out PDPM Clarifications

Article by Skilled Nursing News

The federal government on Tuesday finalized a predicted funding increase for nursing homes, while also formalizing changes to several key quality programs — with an eye toward clarifying some parts of the new Medicare payment model for skilled nursing facilities.

Under the terms of the 2020 final rule for Medicare skilled nursing facilities, the Centers for Medicare & Medicaid Services (CMS) will increase payments to nursing homes by $851 million in the coming fiscal year, which begins October 1 of this year.

That figure represents a slight drop-off from the increase of $887 million projected in the proposed version of the rule, which CMS released back in April; the $851 million comes from a 2.8% increase to the Medicare market basket rate in the final rule, as opposed to a 3% rise in the proposal.

The Tuesday announcement also includes several clarifications related to the Patient-Driven Payment Model, also set to take effect October 1. CMS formally changed the definition of “group therapy” to any modality with two to six residents performing the same or similar activities. That change brings group therapy in SNFs more in line with other care settings, such as inpatient rehabilitation facilities, which use the same definition; CMS currently defines group therapy as activities with exactly four residents.

“As PDPM implementation takes place, CMS believes aligning the group therapy definition serves to improve the agency’s consistency in payment policies across PAC settings,” the agency wrote in a fact sheet about the changes.

Click here to continue reading this article.

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Quality Speech Therapy Programming Under PDPM: 5 Things You Need to Know

Article by:  Sheena Mattingly, HTS Clinical Specialist

Speech Therapy’s role is going to become exceedingly important under PDPM. This is due to the change in reimbursement which will be focused on patient characteristics rather than therapy minutes. Here are the top 5 things you need to know:

  1. Medical complexity and clinical outcomes are the basis for the new patient-driven payment model (PDPM). SLPs will play an important role in determining SNF payment which will require system optimization for timeliness in order to code the most accurate information.
  2. PDPM does not change coverage criteria for skilled care. SNF care is still only covered if all four of the following are met:
    • SNF or skilled rehab services are required to be performed by or under the supervision of professional or technical personnel and is ordered by a physician for the condition which the patient received inpatient hospital services.
    • Skilled services are required daily.
    • Daily skilled services can only be provided on an inpatient basis in a SNF.
    • Services delivered are consistent with the nature of the severity of the illness or injury, medical needs, and accepted standards of medical practice, and are reasonable in duration and quantity.
  3. Understanding the components related to the payment model will help with adjustment to the new system. The need for ST is related to the presence of a swallowing disorder, a mechanically altered diet, a ST comorbidity related, and/or cognitive impairment. Combinations of these characteristics produce 12 ST case-mix groups. Our data analytics have observed a trend in need for optimization especially in section K of the MDS. For this reason, we have created tools and resources to help your SLP, dietician, and nursing staff code section K. Please contact us today for more information!
  4. Sections B, C, K, and I are crucial for accurate coding for the ST reimbursement component. Check out our 5 Day Assessment Tool to optimize IDT communication to improve your coding.
  5. CMS will monitor provider practice during PDPM implementation to audit changes in volume and intensity of therapy services, compliance with group and concurrent therapy limit, and coding practices.
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Exclusive PDPM Training for HTS Partners

Registration NOW OPEN!

We are committed to supporting our partners by offering exclusive PDPM webinar and live trainings in critical areas to foster success as we “Power through PDPM.” Not a partner? Contact us to learn how we’re providing even more value to our partners

 

Supercharge Your MDS:  6-Part Webinar Series

June 14 — Determining Clinical Category & Care Planning for the Complex Resident
June 19 — PDPM: SLP Component & Accurate Reporting of SLP Comorbidities
June 26 — PDPM: NTA Component & Comorbidities
July 10 — PDPM: Section GG & Functional Scoring
July 17 — PDPM: Best Practices for 5-day & IPA Data
July 24 — Transitioning to PDPM & Ensuring Billing Accuracy

New!

July 31 — Supportive Documentation for SNF Level of Care Under PDPM

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The Patient-Driven Payment Model is confirmed to go into effect October 1, 2019

Article by Cassie Murray, OTR, QCP, IASSC CYB, Chief Operating & Clinical Officer, Healthcare Therapy Services, Inc.

On Friday 4/19, CMS released the pre-publication of the FY 2020 Skilled Nursing Facility Prospective Payment System Proposed Rule. As expected, the Patient-Driven Payment Model is confirmed to go into effect October 1, 2019.
SNF Proposed Payment Updates for FY 2020:

  • Proposed SNF payment update is 2.5% (increase of $887 million from FY2019)
  • The proposed updated Base Rates for the PDPM Components (unadjusted federal per diem rates for urban and rural):

TABLE 3: FY 2020 Unadjusted Federal Rate Per Diem–URBAN

TABLE 4: FY 2020 Unadjusted Federal Rate Per Diem-RURAL

SNF Quality Reporting Program:

  • For FY 2022, CMS proposes the adoption of two process measures:
    • Transfer of Health Information to the Provider-Post-Acute Care.
    • Transfer of Health Information to the Patient-Post-Acute Care.
  • CMS proposes to update specifications for Discharge to the Community SNF QRP Measure to exclude baseline nursing facility residents from the measure.
  • CMS proposes to collect standardized patient assessment data using MDS for all patients regardless of payer source.

PDPM Changes:

  • CMS proposes to change the SNF group therapy definition to match the IRF group therapy definition. This would allow for qualified therapists or assistants to treat two to six patients in a group performing the same or similar activities.
  • CMS proposes that non-substantive updates to ICD-10 codes used in PDPM be made through the PDPM website. Substantive changes would continue to be made through traditional notice and rulemaking processes. Non-substantive updates are to maintain consistency with the most recent ICD-10 code set.
  • CMS proposes updates to the regulation text to coincide with the assessment changes under PDPM:
    • Initial patient assessment regulation would state: “assessment schedule must include performance of an initial patient assessment no later than the 8th day of post-hospital SNF care”.
  • The Optional Interim Payment Assessment would be included in the regulation.

Stakeholder comments will be accepted until June 18, 2019.

Click here to view the CMS Fact Sheet.

Click here to view the FY 2020 Proposed Rule Pre-publication.

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7 Things You Can Do Right Now to Prepare for PDPM

  1. Master PDPM Methodology

    Master PDPM methodology and include all staff in job relevant PDPM subject matter trainings. Since we started PDPM training in September 2018, we have seen a trend of key departments who are being left out of the mix. This includes the Admissions teams, floor nurses, social services, medical directors, nurse practitioners, business office and medical records. Needless to say, PDPM will take the village.

    Trainings should Include an intermediate level of PDPM understanding.
    •  ICD-10 Coding
    •  GG Coding
    •  Quick Tip: Coding of the functional status in GG should be based on usual performance and should be determined by IDT collaboration.

     

  2. Ensure Documentation Confidence

    •  Ensure that your nurses are comfortable with the transition from section G to section GG for functional measure coding.
    •      Ensure that the nurses are comfortable with documenting their skill. Since nursing has its own component, they have to be able to “own” their nursing skill and document to justify their services.
    •  Ensure confidence in capturing all active diagnosis. This means that you will need to (or already have) rewritten your admissions procedures and utilize preadmission forms to capture NTA items. Our PDPM analysis across the board shows a great opportunity to improve coding to accurately reflect the conditions of our patients.

     

  3. Set-up for MDS Success

    Set MDS up for success. Evaluate the work flow for MDS and gain an accurate picture of job responsibilities. While there are fewer required MDS assessments under PDPM, the time not spent in assessments can be used to ensure accurate and timely coding under PDPM. Business office managers can begin conversations with managed care providers to ascertain any expected changes in reimbursement.

     

  4. Adapt & Modify Processes

    Adapt and modify your current processes to align with PDPM specific conditions and coding. In our pilot sites, HTS and our partners are adding PDPM processes to current operations to prepare and identify best practice prior to October 1st. This can be achieved alongside our current RUG system to give your team more confidence and reduce the “flipping of the PDPM switch” on midnight of September 30th.

    Examples include:
    Changes to your weekly Medicare meeting forms
    •  Changes to your admission processes Begin a 5-day assessment meeting for all Med A patients with each department contributing their PDPM-related information
    •  Establish the IDT approach to selecting the primary diagnosis prior to the skilled stay.
    •  Use the CMS Clinical Category Mapping “Return to Provider Codes” which will be rejected beginning October 1st

     

  5. Restorative Nursing

    Restorative nursing for your skilled patients may be a positive adjunct to therapy services under PDPM.

    Under PDPM, providing two restorative programs for the nursing groups Reduced Physical Function and Behavioral or Cognitive Symptoms will result in an increased nursing CMI.

     

  6. Talk with Your Docs 

    You have from now until October 1st to work with your hospitals and physicians to ensure efficient data collection for the 5-day MDS and optimal information for coding accuracy. This may include a review of how you obtain your data, what EHR is being used and if they are willing to build reports or have the ability to add reports to their standard transfer paperwork. It may be necessary to call a meeting about PDPM to your referral networks and educate doctors and hospitals on the importance of sending this key information. This includes: providing timely discharge summaries, operative reporting, ICD-10 codes, accurate active diagnosis and any specialty information.

     

  7. Know Your Software

    Whether you are using PCC, Matrix, Vision, etc. it is important to know what new functionalities will be available under PDPM.
    •  Know what current PDPM tools and reports are available for you to take utilize now.
    •  Get involved in any PDPM workgroups offered by the software provider to offer feedback and suggestions.
    •  Take advantage of any trainings, modules or alerts of new functions.

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