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 Are Your Therapists Ready For April 1?
By Becky Smarr Senior Manager, PT, COS-C, Simione Consultants
Many agencies were relieved when CMS decided to delay implementation of the 2011 PPS regulations for therapy until April 1. CMS decided to allow additional "transition time" to prepare for the changes, even though the requirements were "consistent with long-standing CoP requirements and accepted professional standards of clinical practice" which CMS stated providers should have "already adopted."
Among the regulations are:
- Specifications for documenting the therapy evaluation, plan of care and goals
- Requirements for functional re-assessments conducted by the therapist on (or around, in certain cases) the 13th and 19th total therapy visits
- Contents of the functional re-assessment
- Detailed criteria for coverage based on "Expectation of Material Improvement"
With therapy services already on the hot seat for audits and reviews, the new requirements further increase the agency's responsibility for ensuring therapists understand Medicare coverage criteria and provide and document their services accordingly. Action items to prepare for April 1 include:
- Educate therapists on changes to CFR 409.44(c)
- Practice documenting according to the new requirements
- Establish accountabilities for therapists to coordinate their planned schedules with the agency and communicate changes on a daily basis
- Implement the "13-19 Rule" for functional re-assessments and identify effective processes to prevent missing these critical timepoints
- Perform a review of therapy documentation to determine compliance with the new requirements
Simione's Therapy Consultants can assist you in assessing your readiness for April 1. Based on your agency's needs, we can audit to determine your vulnerabilities and education gaps, provide training and education by a therapist for your therapists, or assess your therapy documentation forms for required elements of documentation.
Contact us today to discuss your needs and an individualized plan to meet them. Don't be "fooled" on April 1!
To learn more about our Operations and Clinical Consulting Services, click here or contact Becky Smarr at bsmarr@simione.com
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 COMPLIANCE "TIP"
Don't Risk Losing Home Health and Hospice Reimbursement Because of a DATE!
By Robin Seidman, RN, BSN, MSN, MBA, LNCC, HCS-D, Director, Simione Consultants
CMS recently clarified that physicians must sign and date hospice certifications and home health Plan of Cares, verbal orders, and certifications. This changes CMS's (and the industry's) long standing policy of accepting a date stamp as proof of timeliness in lieu of a physician dating his/her signature. The change was effective for any document requiring a physician signature as of 1/1/11.
It is crucial that all providers take a proactive approach to ensure compliance with the requirement that all physician signatures are dated by the physician's hand:
- Have a process in place that validates all physician signatures and dates (up-front, not at the time of billing)
- Have a send/fax back process that is immediate for incomplete certifications, orders, etc.
- Have an educational tool with the regulatory language "ready" to provide to all physicians who may be having a hard time complying with this new interpretation
- Conduct focused audits after billing to evaluate compliance
- Have an Action Plan ready if documents are identified that are not compliant
For more information about our Compliance Consulting Services, click here or contact Robin Seidman at rseidman@simione.com
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 COST REPORT "TIP"
PS&R Registration
By Maureen Laskowski, Director, Simione Consultants
If you have not previously registered for the IACS system, do so now. The FI/MAC's will not be mailing out the PS&R reports needed to file the cost report. A cost report which is filed late is subject to the provisions in 42 CFR 405.371, which means your Medicare payments will be suspended.
Need help in registering, check out the CMS External User Services (EUS) website which is a dedicated on-line resource providing support for Medicare Providers using the IACS system. The web address is www.eushelpdesk.com/index.html.
For more information about our Cost Report Consulting Services, click here or contact Maureen Laskowski at mlaskowski@simione.com
To view our cost report presentation on the Home Health Cost Report, click here |
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 MARKETING, SALES & CUSTOMER SERVICE "TIP"
Do You Have an Efficient Referral Management System? Part One
By Mike Ferris, Principal, Simione Consultants
Last year, Simione Consultants' Marketing, Sales and Customer Service Division was called on to do what they do best: make referral centers across the country more efficient and enable more referrals and admissions per day to be processed. While we were raising various agencies census' from coast to coast, we uncovered many of the same problems and inefficiencies. While this is just the tip of a very large iceberg, here is one thing you should be looking out for: -Are You Recording All Calls As Potential Referrals, or Classifying Some Calls Into "Information" or "Inquiry" Calls? Nobody wakes up one morning and thinks "I should call a hospice agency today. I've got nothing going on, so it will be good to know this information." 95% of people don't know the right questions to ask or the right information to give us when they call, so the sooner you think of every call as a potential referral, the more you'll realize how many referrals you let slip through the cracks before. To give you my favorite example, a woman called in asking to get a hospital bed and the intake coordinator almost referred them to a DME company. Fortunately, we were sitting right there, doing our on-site coaching, and we had the coordinator ask for more information. It turned out her husband was bedbound with cancer, and the woman calling had seen the hospice deliver a hospital bed to her neighbor therefore, this was the only thing she knew to ask. So get your team to start thinking of every call as a referral before proven otherwise. Watch for Part Two in March For more information about our Marketing, Sales and Customer Service Consulting Services, click here or contact Mike Ferris at mferris@simione.com
Receive complimentary subscription to the bi-weekly eNewsletter, "The Legendary Sales Leadership Letter" to make sure you don't miss a single tip or strategy to increase referrals without increasing costs click here
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