Posted Monday, March 7, 2022
CMS recently announced that it is conducting post-payment review of claims for Medicare Home Health services billed on dates of service from January 1, 2020, through December 31, 2020. Notification that providers will be receiving from CMS will include the reasons for the review, documentation that will be requested in the Additional Documentation Request (ADR) letter, and resources providers may wish to consult when submitting claims.
According to Lisa Newell, Chief Clinical Officer at Corridor, CMS reviewers will be looking specifically at a few key areas especially focusing on therapy:
- Contradictions in documentation
- Functional deficits on their coding, for example, no therapy assessment or when it claims that a nurse claims a patient is independent, but the therapist disagrees.
- Areas that have traditionally been red flags under audit
It is important for agencies to be prepared for what the reviewers are looking for to ensure the best outcome for both the patient and your agency.
There’s no reason you must wait for the CMS contractors’ critical look at your therapy usage and the documentation. When doing your own review, look for the skilled need and medical necessity in visit notes, Newell says. Make sure the notes reflect what the therapist did with the patient, not just the performance of the patient.
“The most common deficit in documentation of therapy visits is that treatment interventions do not reflect the skills of the therapist with the patient,” she says. Instead, they’re an account of the exercises or functional tasks performed by the patient.
Other suggestions on approaching your own therapy review provided by Newell:
- Compare prior level of function to current short- and long-term goals. Short- and long-term goals should be measurable and support meaningful improvement for the patient.
- Consider whether therapy was ordered appropriately for the patient based on functional scores in the OASIS and other documentation.
- Look for plateaus, and whether the plan of care is adjusted when patients are plateauing.
- Ensure staff is clear on maintenance therapy documentation. It is different from a restorative program.
- Look for duplicative treatments from session to session, both within disciplines and across disciplines.
- Reinforce the need. Make sure therapy notes don’t contradict the patient’s homebound status.
For over 30 years, Corridor has partnered with home-based care providers, delivering powerful solutions to support the unique challenges of caring for patients in the home. Our team of operating executives, clinicians, and nationally renowned industry experts have run provider organizations and resolved the same challenges you face.
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