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.


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


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.


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. 😉)

Introducing ... Provider Rating Report Scanner!

As you are probably aware, Broad River Rehab created Staffing Navigator to make it easier for facilities to understand the interaction between staffing levels and star ratings. (If you haven’t heard of Staffing Navigator, check your app store. It’s free and we’ll train you.)

We learned a lot of things creating that app. The original plan was to create a “Quality Measures Navigator” app after Staffing Navigator. We wanted to create something to give people a starting point when it comes to quality measures; a road-map to improving quality measures. There were a lot of disadvantages to doing that. Two of the biggest problems:

  • The data we used for Staffing Navigator comes from the 5 Star Data set. That data is useful for long-term changes like hiring and acuity, but less so for quality measures. Using the 5 star database for quality measures is akin to steering with the rear view mirror. The data is pretty old.

  • When it comes to Quality Measures, we believe that CMS is going to continue to make changes. The quality measures are a moving target. As a result of this, is not so great. The data is spread across at least three tables. Making things more difficult, some measures have different supporting data. In short, CMS doesn’t provide enough data on to accurately recreate the data.

So, we decided to take things in a different direction. We built a tool that will analyze the latest information from your CMS reports and help you find opportunities to improve your quality measures. It even has a simple drag and drop interface.

We’d Like YOUR Help

This tool is brand new and we’d like your help testing it. All you have to do is drop your report on the webpage (link below) and look at the results. We’ll even help you interpret your data!


It’s pretty simple.

  1. Download your “Provider Rating Report”. The date of the report doesn’t matter, but it must be the correct report. The first page should look like the image to the right. If the report doesn’t say “Provider Rating Report”, it isn’t the correct report and will not work.

  2. Head over to our CASPER Report Scanner and upload your report. (Yes, we need a better name. You can use the form below to suggest one!) You can either drag and drop the report onto the tool or click the link to browse to your file.

  3. After the upload completes, results are displayed automatically.

Interpreting Results

The rest of this posting will show you what the results mean.

The summary is the place to start. In this case we can see this is a 2 star quality measure facility. We can also see that this facility is 120 points away from three stars and 76 points away from 1 star. The metric CPP is a measurement that tells you where you are positioned between the cutpoints. A CPP of 0.5 means you are exactly between cutpoints. This facility has an overall CPP of 0.39 meaning it is on the low side of 2 stars.

Taking a look at the long-stay, The CPP of 0.91 means we are very close to the next level of 3 stars. This building is only 9 points away. That means there may be opportunities to pick up a quick 15 or 20 points and hit 3 stars for Long-Stay. The short stay section works the same way. (Keep in mind that the short-stay metric is scaled to match the long stay. If you don’t know what that means then don’t worry about it.)

Long-Stay QM

Moving on to Long-Stay QM. (Note that I’ve switched to a different report for illustrative purposes.)


You can see that this facility is color-coded red, meaning this measure is on the low end of the scale with only 40 points. The rest of the measures are designed to help you understand where you’d need to be in the next quarter.

In this example, the 4.7% is the oldest quarter and will be rolling off. Take a look at the Target column. This represents the value you would need in the new quarter to achieve those points. In this particular case, this facility can do as poorly as 6.96% and still get 40 points. To get to 60 points, this facility would have to get down to 0.64%. This is a level that far lower than they’ve demonstrated recently. This means that while falls are obviously a great concern in this facility, it’s unlikely to net any additional points in the coming quarter. That’s not great news, but it’s better know what you’re up against, right?

Other Metrics:

  • CPP tells us we are on the low end of the cutpoints, but not terribly close to moving to 20 points.

  • Departure from 3Q tells us we could be 2.43% worse than our 3 quarter average and still maintain 40 points.

  • The Up and Down targets are simple differences between your 4 quarter average and the cutpoints. (This is similar to CPP, but some people understand one of the other more easily.)

I’m including a couple more metrics between so you can get a sense of how this works. Try uploading your report to get a better idea. Short-Stay QMs work the same way.

Claims-based measures are displayed a slightly different way since CMS provides different information about those. Take a look at that section on your own.

If you have any questions or comments about this tool, I’d love to hear from you. Use the form below.

We are also looking for a name for this tool. Send me your suggestions!


We’d like to hear from you!

Is this tool helpful? Would you like more? Staffing? Health Inspections? Some other report?

Please send us your feedback, good and bad!

Name *

The DOs and DON’Ts when signing a PDPM Pricing Amendment


  • Options – PDPM is not “one size fits all”, ask for 2 to 3 pricing options from your therapy provider so you can choose the one that you think is best for your facility.

  • Simplicity – You should be able to clearly understand what it is you are paying.

  • Flexibility – Many therapy providers have extensive knowledge of PDPM, no therapy provider has ever implemented PDPM. We have modeled and “hypothesized” what it would look like. Your contract should have an option to review PDPM pricing in 3 to 6 months. This is the only way both the SNF and the therapy provider can ensure their contract is working for both parties.

  • MPPR – Make sure your Medicare Part B services contract has this acronym. IF it does not, there is a strong possibility you are paying more for this service than you are getting reimbursed.


  • A Contract Extension! – Many Therapy Providers are taking this opportunity to slip in a “non-cancellable” 12-month or 24-month contract extension into this PDPM Payment Amendment. So if you current provider is not as good at PDPM as you had hoped, you are stuck with them for a year or more?! They now get to practice PDPM for a year or two at your expense…… That makes NO SENSE for the SNF, but does make a lot of sense for the Therapy Company that is not confident in their PDPM ability and/or knowledge).

DO NOT DO IT! Just say “No”