PDPM Navigator™ Updated!

Based on the information CMS updated on 8-30, we’ve updated PDPM Navigator™. Check the app store for the latest version, 0.4.0.

iPhone users take note: the update takes a little longer with Apple. You should expect to see the update on Thursday!

Thank you to everyone that has installed PDPM Navigator™ and continue to do so. We’re humbled by the response!

CMS Updates the PDPM Website

On Friday August 30th, CMS slipped in a PDPM website update, presumably with the latest revisions to the PDPM that seem to be a natural result of questions and clarifications arising from the Final Rule posting in July, the two training sessions that CMS provided in Kansas City and Baltimore as well as the recent open Door Forum. It is imperative that providers review the website in its entirety to be sure that they are up to speed with the latest policy specifics.

Here is a summary of these revisions;

  1. The ICD-10 Mapping tool has been updated including the maps for Clinical Category Placement into PT, OT and SLP, as well as the comorbidity maps for SLP and NTA. Within theses maps CMS has added a significant number of codes. The Clinical Category map has swollen to 72,184 codes including 34,872 RTP codes. The NTA comorbidity map now contains 1,806 codes, an increase of 271 codes.
  2. Five of the nine PDPM FACT sheets have been updated with redlines to indicate the change.
    1. Concurrent and Group Limit FACT Sheet – The definition of Group Therapy has been updated to reflect the definition that was finalized in the Final Rule: “Group therapy is defined for Part A as the treatment of 2-6 residents, regardless of payer source, who are performing the same or similar activities, and are supervised by a therapist or an assistant who is not supervising any other individuals.”
    2. Functional and Cognitive Scoring FACT Sheet – The necessity of a BIMS score to the SLP category calculation has been revised to indicate: “In cases where neither the BIMS nor the staff assessment is completed, the patient will be considered “cognitively intact” for classification purposes under PDPM.”
    3. Interrupted Stay FACT Sheet – The definition of the Interruption Window has been revised relative to the new Interrupted Stay Policy: “The interruption window is a 3-day period that begins on the first non-covered day following a Part A-covered SNF stay and ends at 11:59pm on the third consecutive non-covered day. It should be noted that the first non-covered day may be different depending on if the patient leaves the facility or simply leaves Part A coverage.”
    4. MDS Changes FACT Sheet – The use of the optional State Assessment has been clarified and the time limitation on the use of the OSA has been removed: “Second, for states that rely on the RUG-III or RUG-IV assessment schedules for calculating case mix group for NF patients, CMS has created the optional state assessment (OSA) so that Medicaid payments are not adversely impacted when PDPM is implemented as of October 1, 2019. States will have the ability to determine the policy associated with this assessment to meet your Medicaid payment needs. The optional assessment will be in place from October 1, 2019 through September 30, 2020.
    5. PDPM Patient Classification FACT Sheet: The PDPM Classification Group tables have been updated to reflect the revised case mix weights that were published in the Final Rule.
  3. The PDPM FAQ document has been revised and new Q&A has been added.
    1. The TOC has been revised to accommodate the new Q&A numbers and the new numbers have been added throughout.
    2. Q 1.5, Clarification has been added as to which assessments will be used for Part A billing: “How do providers bill for services under PDPM? Providers would bill for services under PDPM using the Health Insurance Prospective Payment System (HIPPS) code that is generated from assessments a 5-day PPS assessment and Interim Payment Assessment (IPA) with an ARD on or after October 1, 2019.”
    3. NEW Question 1.9, “Is it required that the SNF primary diagnosis match the primary diagnosis reported for the qualifying hospital stay? No, the primary diagnosis for the SNF stay may differ from the primary diagnosis reported for the hospital stay that serves as the qualifying hospital stay necessary for SNF coverage.”
    4. Q 5.4 has been revised to reflect a very important update as to how the BIMS score will impact the SLP classification: “How is the patient classified under PDPM if neither the BIMS nor the CPS staff assessment is completed to determine cognitive level? If neither the BIMS nor the staff assessment is completed, then a patient will be classified under PDPM as if the patient were “cognitively intact.” In other words, even if the patient has a cognitive impairment, without the BIMS or staff assessment completed, the cognitive impairment will not be considered as part of the patient’s PDPM classification. An IPA may be done to reclassify the patient in such scenarios to capture the cognitive impairment.”
    5. Q 11.2 has been corrected to appropriately refer to MDS item I0020B.
    6. Q 12.10 has been revised to clarify the concept that while an EOT is not necessary under PDPM, a daily skilled care requirement is: “If there is a three-day break in therapy will an EOT be required under PDPM? Under PDPM, there are not a required number of days of treatment per week in order to receive a certain therapy component classification (thus no EOT will be required); however, there is still a daily skilled care requirement for SNF Part A patients, as discussed in Chapter 8 of the Medicare Benefit Policy Manual, specifically section 30.6.
    7. Q 13.3When is a stay considered “interrupted” under the Interrupted Stay Policy?”, has been revised to include reference to the revised definition of the interruption window that can be found in the interrupted Stay FACT sheet.
    8. Q 13.7What is the “interruption window?” has been revised to include an expanded definition of the interrupted stay that is found in the Interrupted Stay FACT Sheet. Old Q 13.9, which contained the previous definition of the Interrupted Window, has been removed. Q13.10, 13.13 and 13.16 have been edited to remove portions of the old Interruption Window definition. The revised expanded definition is: “…beginning on the first non-covered day following a covered SNF Part-A stay and ends at 11:59 pm on the third consecutive non-covered day. It should be noted that the first non-covered day may be different depending on if the patient leaves the facility (facility discharge) or merely is discharged from Part A but continues in the facility under a different payer (Part-A discharge).
    9. New Q 14.15 has been added: “I have questions about the OSA. To whom should I direct these questions? Any questions regarding the OSA should be directed to the relevant state agency governing the state’s Medicaid policy issues.

Striving for Compliance

We all say we want compliance, but do we strive for it?  My philosophy professor in college used to emphasize that you must define what you are discussing so that you can discuss it intelligently.  So let’s define “compliance” in medical record documentation.  For this blog we will define compliant documentation as “accurately recording the care you have provided per the rules and regulations that govern us” In skilled nursing facilities we are regulated and governed in large part by CMS and the RAI manual.  Let’s narrow our scope here to being compliant with the MDS.  For MDS purposes we must document per the rules of the RAI manual. I talk to many facilities about their ADL documentation and they readily admit their CNAs consistently inaccurately code the care they have provided per Section G of the RAI manual.  So not only do they not get paid appropriately, they are out of compliance by definition, AND ITS ACCEPTED!    Is it better to be compliant and get paid more OR be non-compliant and get paid less?  That sounds absurd, but I meet many MDS coordinators, DONs, Administrators, and Owners that accept inaccurate (read: out of compliance) Section G coding for multiple reasons….. “It too hard to teach” or  “They have always coded this way”  or “We have all new staff” etc….

PDPM is coming and now striving for compliance is becoming a BIGGER issue.  Medicare Part A just got much more complicated with hundreds of items now contributing to our reimbursement in Section GG, Section K, Section I, Section H, Section , Section M, Section O Section D Section J, and MORE!!! I believe some will continue to accept inaccurate and non-compliant documentation and get paid less and struggle more.  I also believe some will “strive” for compliance and accurately code the MDS per the rules/definitions in the RAI manual and will thrive under PDPM

North Carolina Medicaid Trends Continue

In every state we analyze that has a case-mix system there are certain trends that we see over and over. Two of the most common trends are:

  • Average case-mix slowly increases over time. This is true even in states that have a budget neutrality factor (BNF). North Carolina doesn’t have a BNF. In states that do have a BNF, it really is true that if your case-mix isn’t increasing, your reimbursement will decline slowly over time.

  • The percentage of residents with a therapy RUG slowly increases over time. You can almost tell how long a state has been on case-mix by the percentage of rehab RUG days. This is true even in states that don’t use a “point in time” or “picture” date.

Let’s check out the latest quarterly data from the state of North Carolina.

Casemix.PNG

Case-mix continues its slow, unsteady climb upward. This isn’t surprising or new. The magnitude of the uptick is high, but not unprecedented.

Rehab.PNG

The same general trend appears here. Therapy is driving case-mix higher over time. If you are a long time reader of this blog this might look like a re-post. The “Therapy is driving case-mix higher” trend continues.

ADL.PNG

Providers continue to lose ground and under-code here. Even providers that understand ADL coding and how important it is, struggle to get accurate coding consistently over time.

Key Points

  • Accurate, consistent ADL coding is hard. That’s why Broad River Rehab spends so much time and effort on ADL training. (Seriously, we have: mobile training software, we do on-site, all-shift training sessions, we have training videos for our customers to use and we even put our own CNAs in facilities to code ADL activity that occurs during the delivery of therapy.) If you are in a case-mix state, Section G is important and isn’t going anywhere anytime soon, even while you focus on PDPM.

  • Speaking of PDPM, the next several quarters of data are going to be interesting. Will providers let ADLs slip further as they adjust to PDPM? Will we see a larger than normal increase in rehab days for Medicaid? Stay tuned. These are interesting times.

If you want to analyze your ADL scoring performance or talk about ways to improve your documentation compliance AND case-mix, contact us!

Document Navigator!

Document Navigator!

Broad River Rehab is beyond excited to announce our Document Navigator! It uses cutting-edge AI technology to quickly read your patient documentation and find everything from non-therapy ancillaries to medications! You simply drag and drop a document onto a web page. We’ll scan it and highlight all the important items so you can find those ICD-10 codes, NTAs and much more. This isn’t some keyword scanner either. It uses the latest artificial intelligence to understand medical terms, including dates, diagnoses, tests, acuity, treatments and even the difference between generic and brand name medications! There’s even more. We can’t wait to show it to you!

With PDPM coming, the time period to read and understand incoming documentation is getting shorter. The stakes are higher as well. Missing an NTA on the 5 day will cause financial harm that can’t be fixed. You can’t afford to routinely miss important information and you sure don’t want to do an IPA if you don’t have to.

But Document Navigator isn’t just for Part A! Wouldn’t it be nice to have a list of medications prior to admission? Document Navigator can scan a 30-page document in just minutes, summarize and make recommendations!

We are really excited about this and hope you are too. We’re also thrilled to add this to our suite of outstanding software tools to make you more efficient!

You’ll be seeing a lot more announcements about Document Navigator in the coming days and weeks! Stay tuned!

In the meantime, here are a couple of images from Document Navigator. (Blog subscribers, you may need to click the link to the actual posting to see these, sorry.)

Contact us today! There’s still time to get Broad River Rehab in your building and yes, we’ll start on October 1st if you’d like. (You won’t be the only one. 😉)