PPS payment update provides a slight increase, but few
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1. Page 6 PPS Alert for Long Term Care October 2012 from coding billing and IT as well as doctors and nurses who can help with the specific clinical translations Duchek says This committee should look at ways the new system will affect software hardware storage and paper processes how patients will be impacted and where their facility is in terms of making this switch gt Identify software needs Software upgrades may be necessary to house the additional 140 000 codes included in ICD 10 as well as the existing ICD 9 codes which will continue to be used for inpatients with a discharge date prior to October 1 2014 or if there is an issue with rebilling Now is the time to look at the reports you re getting from your practice management system or EMR to identify the ICD 9 codes you use most often Duchek says Identifying your top revenue codes is a good place to start with mapping ICD 9 to ICD 10 You will also want to con firm that your ICD 9 reports will be converted to ICD 10 Establish a lead contact within the facility Facilities should also appoint a designated point per son that is going to be the resident expert in the new system and lead the transition MDS coordinators are typically the ones who handle the current ICD 9 system so the responsibility will most likely fall to them although a team approach may be necessary Mines says With the new system there might be the need t2. she says As part of the Affordable Care Act CMS has already launched its Quality Assurance and Performance Im provement QAPI project in nursing homes across four states California Florida Massachusetts and Min nesota in order to test tools and resources and solicit feedback before the national rollout Another program conducted at 182 SNFs in Wisconsin New York and Ari zona yielded mixed results leaving health officials un sure whether it would result in net savings or improved quality care This should be a warning shot for long term care facilities if they want to remain financially viable since quality will ultimately impact reimbursement rates says David Bufford an attorney at Hall Render Killian Heath amp Lyman PSC in Louisville Ky The future for nursing homes in general is they are going to be paid on a quality basis Bufford says QAPI is really going to be the basis of how they are going to be reimbursed in the future You are going to have to meet certain quality initiative guidelines to essentially achieve the same amount of reimbursement It s important that facilities also look at implementing an IT infrastructure that will allow them to effectively track quality data Many of the national organizations have already invested in this so they can communicate better with acute care organizations but many of the smaller mom and pop organizations still lag behind If they don t get
3. sician practices would face operational difficulties and could even be forced to close their practices Given the struggles the healthcare industry had with Version 5010 there were plenty of concerns among long term care providers that implementing an even more complicated system in ICD 10 would be extremely difficult by the October 2013 deadline says Dawn Duchek industry initiatives coordinator for Gateway EDI in St Louis 5010 had a much bigger impact to the industry than was expected Duchek says The goal with ICD 10 is to have a much smoother transition and to better prepare for the potential bumps in the road From a financial perspective a regulatory impact analysis conducted by HHS showed a cost avoidance of 3 6 8 billion that would incur if healthcare providers For permission to reproduce part or all of this newsletter for external distribution or use in educational packets contact the Copyright Clearance Center at www copyright com or 978 750 8400 October 2012 PPS Alert for Long Term Care and plans had to process claims manually and smaller healthcare providers would have to take out loans as a result of delayed payments A new date with the same changes Aside from the date nothing has changed in terms of the impact of the transition from ICD 9 CM to ICD 10 CM These new diagnosis codes are still much more specific than the ICD 9 version ICD 9 codes are three to five characters whereas ICD
4. 10 codes are three to seven characters and alphanumeric offering more detail and specificity for certain conditions For example under ICD 9 pressure ulcers were coded as 707 0x and 702 2x in order to define the scope and stage ICD 10 gets far more specific with more than 100 codes for pressure ulcers that define the location laterality and stage of the wound Once implemented the specificity of ICD 10 CM coding will paint a fuller and more detailed picture of the resident in the UB 04 form which should ultimately reduce the number of denials to SNFs The system will also be able to better handle the transition to electronic medical records EMR by providing more current information on a resident s condition and staying cur rent with terminology and clinical concepts Although the transition to ICD 10 is on the horizon facilities still need help fully understanding the current ICD 9 system says Marilyn Mines senior manager of clinical services for FR amp R Healthcare Consulting Inc in Deerfield Ill These misconceptions will only make the transition more difficult There s a lot involved in ICD 10 that is not under stood she says I m not sure how SNFs are going to be able to move to the specificity of this coding when the current coding is not always being done correctly Approaching the change The following are suggested steps facilities can take to facilitate a smooth transition to ICD 10 gt
5. 781 639 1872 Ext 3505 Email mdamico hcpro com ion or use in educational packets contact the Copyright Clearance Center at www copyright com or 978 750 8400 October 2012 PPS Alert for Long Term Care Page 3 Foster the SNF will have to find ways to work around both schedules To resolve these issues it s imperative that thera pists are included in the care plan process Foster says With this approach therapists can communicate with the doctors and nurses to determine what other health complications the patient is dealing with and they can push for restorative therapy programs so there is some continuity between what the therapist is doing and what the clinicians are doing In some facilities therapists operate in their own bubble which can cause confusion with nurses and nursing assistants They are a really big part of the team Foster says With this team approach the patient might actually need more therapy There are solutions but they have to be part of the team This confusion can also create discrepancies between the patient chart and billing and MDS forms For example an occupational therapist might be working with a patient to teach the patient to dress him or herself but in the nursing documentation the nurse would note that the patient dressed him or herself leading a Medicare auditor to question why the occupational therapist is getting paid to teach the patient what he or she already
6. begin the process of evaluating how they will make the transition We had the interim final rule in February and now six months have gone by so if you haven t done anything what have you gained You ve only gained six months Duchek says The longer you procrastinate the less time you have to get ready There are so many things that a facility or practice can do today that can help them with the processes right now and help them to understand the impacts of ICD 10 Mines recommends initiating a task force at the beginning of 2013 to get the process started by identi fying a few key leaders to look at how new codes will be implemented and how they will affect the facil ity s current billing system This committee should also look at their percentage of rejections and appeals with ICD 9 whether those will increase or decrease with ICD 10 and how they can maximize reimbursement by accurately applying the new system I would say right after the beginning of the year is when people should sit down with their teams and figure out what they re going to do and set up a sched ule of events so when the date actually comes they won t be out of their minds to figure out what to do Mines says E For permission to reproduce part or all of this newsletter for external distribution or use in educational packets contact the Copyright Clearance Center at www copyright com or 978 750 8400 October 2012 PPS Alert for Lo
7. care clinicians to easily search for the condition they need to treat and access the appropriate checklist within seconds Each checklist can be downloaded and printed to fit directly into the resident s record to ensure thorough focused and regular assessments and documentation for every resident For more information about this product visit HCPro at www hcmarketplace com prod 9750 For permission to reproduce part or all of this newsletter for external distribution or use in educational packets contact the Copyright Clearance Center at www copyright com or 978 750 8400 Page 8 PPS Alert for Long Term Care October 2012 poor quality hanging over them for decades she says Possibly more than any other provider type they have had to work harder to overcome the preconceived notion of poor quality that was prevalent on the con sumer side The long term care industry had been concentrating on quality delivery of care and quality of life long before the mandates started coming from CMS Now that quality measures will be added to the Nursing Home Compare website a public venue nursing homes will need to concentrate not only on quality of care in general but specifically in those measures that will be included Quality care has always been a focus for long term care facilities but these objectives help bring it to the forefront Potter says Every facility has a different area to focus on in terms of
8. improving quality care If you already have an effective program this action plan should prompt you to redefine the scope of your pro gram or reveal additional weaknesses For those that don t have a strong quality improvement program this serves as a reminder that they may need to rebuild Specifically organizations need to be looking at many of the same initiatives that have been highlighted by CMS all year such as reducing rehospitalization rates use of antipsychotic medication and pressure ulcers says Maureen McCarthy RN BS vice presi dent of clinical reimbursement for National Healthcare Associates and president of Celtic Associates LLC in Goshen Conn McCarthy suggests breaking down specific sections of the plan to determine how those objectives relate to your particular facility For example what are your rates Relocating Taking a new job AES If you re relocating or taking a new job and would like to continue receiving PPSA you are eligible for a free trial sub scription Contact customer service with your moving information at 800 650 6787 2012 HCPro Inc for antipsychotic drug use and what should your rates be to achieve the 15 reduction CMS has requested Where are patients being unnecessarily rehospitalized and what can you do to improve that process or commu nication among clinicians You need to know where you are before you know where you re getting to and how long that road is
9. knows how to do If the therapist were included in a meeting with the nurse that detail could have been resolved That could be a major monetary payback Foster says You can t do anything about that because it s already charted You can t go back and erase it or change it Triple check your documentation Many facilities are likely still feeling the impact of last year s Medicare cuts as well as the Medicaid rates that were either cut or maintained at the state level These payment decreases have only highlighted the need for accuracy so SNFs are fairly compensated for the care they provide During a time of increased scru tiny from CMS regarding overpayment and Medicare fraud SNFs need to be particularly aware of their 2012 HCPro Inc billing and coding documentation which is the back bone of a CMS audit SNFs need to be monitoring the care that they are providing and making sure they are coding that care accurately and triple checking the billing with the MDS to make sure everything matches up correctly Hopp says Providers really just need to continue doing what they have been doing but just make sure everything is as accurate as possible Audits can be extremely nerve racking for a facility and the results can be equally detrimental Foster says Even the slightest discrepancy can affect reimbursement rates particularly when it comes to therapy and RUGs I don t think I ve
10. Assemble a steering committee The first step in making the transition to ICD 10 CM is to assemble a steering committee made up of representatives CPro Advisory Services Customized guidance from a trusted source The demands on long term care providers have never been greater HCPro s Advisory Services are outcome driven individualized solutions to meet your most complex regulatory financial and operational challenges Our value lies in the unique partnership we build with providers and the results we help them achieve There is nothing standardized about our approach we will evaluate your current processes and outcomes create action plans to improve them build tools to use in practice and implement a system for sustainable results Our team of advisors offers a full range of services to long term care providers including e Documentation Improvement Review e Survey Preparation and Response e Case Mix Analysis e MDS 3 0 amp RUG IV Review e Compliance Program Development e Medicare Coding and Billing Audits To discuss your needs with lead advisor Diane Brown please call 877 233 8828 for a free no obligation conversation about how HCPro Advisory Services can benefit you today www hcpro com LTCadvisory 2012 HCPro Inc For permission to reproduce part or all of this newsletter for external distribution or use in educational packets contact the Copyright Clearance Center at www copyright com or 978 750 8400
11. Ever since the Office of Inspector General OIG p 11 PPS Q amp A yee released the report Questionable Billing by Skilled Regulatory specialist Diane L Brown BA CPRA discusses significant ae change criteria coding for IV fluids and requirements for EOT OMRAs Nursing Facilities in December 2010 CMS has been more actively involved in cracking down on facilities Page 2 PPS Alert for Long Term Care October 2012 that may be getting inflated reimbursement Looking at data from 2006 to 2008 the report found that SNFs increasingly billed Medicare for higher paying RUG rates even though patient characteristics remained largely the same The report found that payments to SNFs with ultra high therapy RUGs increased 90 during that time period accounting for a 5 billion increase in payments As a result OIG recommended that CMS monitor payments from SNFs particularly those that are billing for higher paying RUGs and change the current method for determining how much therapy is needed to ensure appropriate payments CMS has been closely monitoring the amount of individual concurrent and group therapy so providers obviously need to provide what is most appropriate for the resident says Julia Hopp MS RN NEA BC Editorial Advisory Board HCPro PPS Alert for Long Term Care Assoc Editorial Director Elizabeth Petersen Associate Editor Melissa D Amico mdamico hcpro com Contributing Editor Evan Sw
12. October 2012 Vol 15 No 10 An Integrated Approach to the LTC Industry PPSA ERT PPS p aym ent upd ate significant increase from last year s 11 1 Medicare s d li h reduction The overall market basket increase is 2 5 for provi esas ig t increas e SNFs but a 0 7 adjustment as part of the Affordable but few ch anges Care Act s 10 year plan to reduce Medicare knocks down the overall increase CMS estimates this will translate to A Continuing Education Learning Objectives an influx of approximately 670 million Also of note CMS decided to forgo the usual rule After reading this article you will be able to making process by gt Identify the changes made by CMS to the SNF PPS skipping the comment The positive thing is for fiscal year 2013 i period and simply is that there is an increase gt Describe the impact these changes may have on suing the final rule in We never thought there a facility s coding and billing practices July In April CMS would be one Even gt Describe the impact these changes may have on though it s small I think that s positive A announced that rather a facility s documentation practices than proposing new regulations that could Bonnie G Foster There is a saying that goes Something is better than radically affect pay RN BSN M Ed nothing which is the mantra SNFs should have for the 2013 fiscal year In July CMS officially released an up
13. date notice regarding the SNF PPS for fiscal year 2013 CMS has issued a 1 8 increase to the market basket rate a ments it would simply make statutory update adjustments to Medicare Part A enabling it to forgo the comment period Although it s a fairly insignificant increase SNFs should be relieved that it s not another year of drastic cuts says Bonnie G Foster RN BSN M Ed owner and presi IN THIS ISSUE dent at Foster Consulting Inc in Columbia S C The positive thing is that there is an increase p 4 ICD 10 postponed until 2014 T C P r O On August 24 HHS issued the final ruling Foster says We never thought there would be one confirming a one year extension of the ICD 10 compliance deadline Find out what this means for your facility On the other hand the slight increase reinforces the Even though it s small I think that s positive importance for facilities to focus on the accuracy of their p 7 CMS Nursing Home Action Plan focuses on quality and patient cate coding and Medicare billing as well as how patients Learn more about CMS 2012 Nursing Home Action Plan which supports are receiving therapy an issue that CMS has been the three part directive from the national organization to improve healthcare in the United States monitoring closely p 10 MDS professor Think you re an MDS expert Test your knowledge of this long term care Watch your RUG rates t tool with iz Sa ampere
14. ders 101 payers and 90 vendors to determine how well prepared the industry was for these changes CMS found that 83 of providers were aware of the upgrade to Version 5010 but only 64 indicated they would be compliant by the January 2012 deadline Additionally nearly a quarter of providers in the survey 2012 HCPro Inc indicated they would not be ready for the ICD 10 October 1 2013 deadline Another survey conducted by the American Health Information Management Association in September 2011 had mixed results from 639 providers concerning com pliance efforts with Version 5010 and ICD 10 Although 85 of inpatient facilities had begun preparing for the implementation of ICD 10 39 3 of all other provid ers had not started planning at all Furthermore of the other providers that hadn t started implementation planning 50 5 indicated they weren t sure when this planning would begin Lastly according to a survey by the Workgroup for Electronic Data Interchange conducted in February 50 of respondents indicated they didn t know when they would complete their impact assessment of the ICD 10 transition Even after the January deadline for Version 5010 healthcare organizations particularly smaller organizations continued to struggle In February the Medical Group Management Association sent a letter to HHS indicating that if the government didn t step in to help solve the problems with transitioning to 5010 phy
15. dressing benefit but in this case it is being used on an area that is not a wound and has not met the debridement criteria as established in the surgical dressing medical policy 8 a amp c Ostomy supplies and surgical dressings do not currently have this requirement 9 a True Either can occur depending on the type of medical review PPSA Subscriber Services Coupon QO Start my subscription to PPSA immediately Options No of issues Cost Shipping Total Q Electronic 12 issues 239 ppsae N A O Print amp Electronic 12 issues of each 239 ppsape 24 00 Order online at www hcmarketplace com Sales tax see tax information below Be sure to enter source code N0001 at checkout Grand total For discount bulk rates call toll free at 888 209 6554 Tax Information Please include applicable sales tax Electronic subscriptions are exempt States that tax products and shipping and handling CA CO CT FL GA IL IN KY LA MA MD ME MI MN MO NC NJ NM NV NY OH OK PA RI SC TN TX VA VT WA WI WV State that taxes products only AZ Please include 27 00 for shipping to AK HI or PR HCPro 2012 HCPro Inc Mail to HCPro P O Box 3049 Peabody MA 01961 3049 Tel 800 650 6787 Fax 800 639 8511 Email customerservice hcpro com Web www hcmarketplace com Your source code N0001 Name Title Organization Address City Stat
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17. ea The dressing to the left hip is a c A SNF may obtain a supplier number and be able to submit claims to the DMERC d Submission of claims to the DMERC is done gauze dressing with hydrogel for a Stage 3 wound Which of the following supplies are not covered CMS 1500 f d HCPCS a Duoderm sing a CMS orm and appropriate using pprop ee codes c Gauze d Tape 3 Which of the following services requires a See Coun eC ee t bE 8 Which of the following prosthetic supplies requires signed by the supplier before submitting a claim the test of permanence condition for at least a Urological supplies three months to be covered by Medicare b Surgical dressing supplies a Trach care supplies c Enteral therapy supplies b Ostomy supplies d Ostomy supplies c Urological supplies d Surgical dressings 4 Which of the following diagnoses would meet the cri teria for enteral therapy 9 Medicare medical review can occur either post to be covered payment or prepayment a Left hip fracture a True b Pneumonia b False c Blindness d CVA with dysphagia Answers to these questions are on p 12 E 2012 HCPro Inc For permission to reproduce part or all of this newsletter for external distribution or use in educational packets contact the Copyright Clearance Center at www copyright com or 978 750 8400 October 2012 PPS Alert for Long Term Care Page 11 PPS Q amp A Editor s note This month s PPS Q A wa
18. eeney Diane L Brown BA CPRA Mary C Malone JD Regulatory Specialist and Boot Camp Instructor Healthcare Attorney Director HCPro Inc Hancock Daniel Johnson amp Nagle PC Danvers Mass Richmond Va Maureen McCarthy RN BS CPRA Director of Medicare Regulatory Compliance and Education National Healthcare Associates Goshen Conn Frosini Rubertino RN CPRA CDONA LTC Executive Director Training in Motion LLC Bella Vista Ark Rena R Shephard MHA RN RAC MT C NE President RRS Healthcare Consulting Services San Diego Calif Holly F Sox RN BSN RAC CT MDS Coordinator Presbyterian Communities of South Carolina Lexington S C Sandra Fitzler Senior Director of Clinical Services American Health Care Association Washington D C Bonnie G Foster RN BSN M Ed Long Term Care Consultant Columbia S C Cindy Frakes Owner Winter Meadow Homes Inc Topeka Kan Julia Hopp MS RN NEA BC Executive Vice President of Reimbursement Paramount Health Care Company Garden Ridge Texas Steven B Littlehale MS GCNS BC Executive Vice President Healthcare Chief Clinical Officer PointRight Inc Lexington Mass PPS Alert for Long Term Care ISSN 1521 4990 print 1937 7428 online is published monthly by HCPro Inc 75 Sylvan St Suite A 101 Danvers MA 01923 Subscription rate 239 year PPS Alert for Long Term Care PO Box 3049 Peabody MA 01961 3049 Copyright 2012 HCPr
19. ever been through an audit where a facility didn t have to pay back some money and we re talking thousands and thousands of dollars Foster says However SNFs can minimize that damage by reinforcing a team centered approach to patient care and training clinicians and coders on the effects of improper documentation The problem is that it s usually very simple stuff stuff you don t even think about Foster says But once you ve been audited you re on their list and then you re always on their list E Gain QM confidence with our upcoming webcast Quality measures QM are back The blackout period is now over and there are updates you need on regulations pertaining to the use of the QMs and the three QM reports that surveyors issue to providers During this 90 minute broadcast our expert speaker will identify the triggering criteria high risk areas how MDS driven QMs are calculated and the impact of the threshold comparison adjustment For more information about this webcast visit HCPro at www hcmarketplace com prod 10503 For permission to reproduce part or all of this newsletter for external distribution or use in educational packets contact the Copyright Clearance Center at www copyright com or 978 750 8400 Page 4 PPS Alert for Long Term Care October 2012 ICD 10 postponed until 2014 giving facilities another year to p
20. g to the billing office manager to volunteers should be prepared to answer surveyors questions Potter suggests utilizing an outside consultant who will conduct an unbiased mock survey in order to highlight weaknesses More intensive focus on quality care and reducing re admissions means surveyors will likely be more diligent in their process Bufford says This will be particularly true in facilities where they have immediate access to electronic medical records where they can hone in on 12 patients with chronic obstructive pulmonary disease or 12 patients on a feeding tube rather than 12 random patient files I think what we are going to see in the future is because of the quality initiative requirements they aren t going to just take the facility s word for it Bufford says There is going to be a little more digging Survey preparation will be particularly important as CMS unveils more quality improvement surveys and reimbursement is tied to specific objectives 2012 HCPro Inc Building a team approach Long term care facilities would be remiss not to use this action plan as an opportunity to improve upon all facets of their organization Based on the objectives and approaches that CMS lays out facility administrators can conduct a risk analysis of their entire facility Potter says This should include heavy involvement from the clinical team as to what areas need more attention as well input from socia
21. he resident continues to make steady progress under the current course of care Reassessment is required only when the condition has stabilized gt Instances in which the resident has stabilized but is expected to be discharged in the immediate future The facility has engaged in discharge planning with the resident and a comprehensive reassessment is not necessary to facilitate discharge planning 2012 HCPro Inc CMS clarified that we do not have to do an End of Therapy EOT if a resident is discharged from the facility on day 3 after one to three days of no therapy What if day 3 is the resident s last covered day Are we required to complete an EOT A If the resident is discharged before midnight of the third day you are not required to complete the EOT OMRA Does coding for IV fluids in Section K for the seven day look back period affect the RUG level and reimbursement rate A Yes it does impact the RUG IV level and reim bursement category By checking IV fluids in MDS item K0510A the beneficiary will classify into the Special Care High category Hxx Don t forget to re view the instructions in the MDS User s Manual before checking this item to be sure the resident meets the requirements 0 Regarding the ability to make self understood and understanding others B0700 B0800 if the resident has one day in a seven day period that he is acutely ill and has a decrease in his level of consc
22. ious ness and was not able to communicate would that be coded as 3 rarely never understood or should the com plete seven days be taken into consideration The assess ment is a discharge assessment and some think that the Don t miss your next issue If it s been more than six months since you purchased or renewed your subscription to PPSA be sure to check your envelope for your renewal notice or call customer service at 800 650 6787 Renew your subscription early to lock in the current price For permission to reproduce part or all of this newsletter for external distribution or use in educational packets contact the Copyright Clearance Center at www copyright com or 978 750 8400 Page 12 change in level of consciousness should be noted on the assessment somehow A Although ADLs code the worst moment that happens three or more times other items such as ability to make self understood do not It s looking at the entire seven days rather than the one unusual day Your documentation should include the one day event but your coding should look at all seven days If a resident is on IV therapy should this informa tion be coded in Section K under parenteral IV or is PPS Alert for Long Term Care October 2012 this for nutrition only A The question you need to answer is Why is the resident on IV therapy You can only code IV therapy that is provided for either nutrition or hydra tion inc
23. l workers therapists and dietary and environmental services employees Improvement will only come from an interdisciplin ary team approach to finding areas of weakness and turning them into strengths Potter says In general a multidisciplinary approach will bring a variety of perspectives and will help meet the goals that CMS has set forth in its action plan E Learn how to run a successful SNF The Comprehensive Guide to Nursing Home Administra tion written by Dr Brian Garavaglia serves as a blueprint to managing staff developing a budget and navigating the ever changing SNF regulatory environment Com plete with an emphasis on high focus survey targets such as Medicare reimbursement quality care and documenta tion this book also contains more than 850 downloadable test questions to ensure SNF administrators are well pre pared to improve operational efficiency This book will help you gt Create a culture of communication within your facil ity and efficiency by clearly defining staff roles and responsibilities Achieve regulatory compliance by being survey ready at all times through implementation of appropriate policies and procedures Reduce nursing home staff turnover by hiring the most qualified employees and supporting them with effective training For more information about this product visit HCPro at www hcmarketplace com prod 10292 For permission to reproduce part or all of this new
24. luding prevention of dehydration The RAI User s Manual states KO510A includes any and all nutrition and hydration received by the nursing home resident in the last 7 days either at the nursing home at the hospital as an outpatient or an inpatient provided they were administered for nutrition or hydration E MDS professor answer key Below are the answers to the MDS professor on p 10 1 c Both revenue codes should be billed 2 b Only PEN supplies must be billed to the DMERC Prosthetic and orthotic supplies may be billed to the A B Medicare Administrative Contractor MAC 3 c Only enteral and parenteral therapy supplies require an additional document referred to as the Certificate of Medical Necessity All other supplies require only the presence of a specific physician order 4 d A CVA with resulting dysphagia meets the coverage criteria described under the medical policy for enteral feeding The diagnosis must relate back to the reason the patient cannot eat an oral diet 5 False If documentation is not received in 45 days a medial review determination will be made on the information available which could include a full denial 6 d Irrigations that are routine are not covered under the urological medical policy Only irrigations that are nonroutine and are used for an acute problem such as an acute blockage of the catheter are covered 7 a Duoderm is a covered product under the surgical
25. ng Term Care Page 7 CMS Nursing Home Action Plan focuses on quality and patient care A Continuing Education Learning Objectives After reading this article you will be able to gt State the main objective of CMS 2012 Nursing Home Action Plan gt Describe the five approaches CMS suggests nursing homes should take to meet the plan s objectives gt Recognize the impact these objectives have on maintaining quality of care for nursing home residents CMS has released its 2012 Nursing Home Action Plan which supports the three part directive from the national organization to improve healthcare in the United States The three objectives are gt Improving the individual experience of care gt Improving the health of populations gt Reducing the per capita cost of care for populations In an attempt to meet these three overall objectives CMS has laid out five approaches for nursing homes to consider going into next year gt Enhance customer engagement with relevant timely information that can be accessed by the public Strengthen survey processes standards and enforce ment by improving the way data is captured and im proving the consistency with which nursing homes are regulated gt Promote quality improvement by reducing physical restraints rehospitalizations and the prevalence of pressure ulcers as well as supporting institutional culture change gt Create strategic approaches thro
26. o Inc All rights reserved Printed in the USA Except where specifically encouraged no part of this publication may be reproduced in any form or by any means without prior written consent of HCPro Inc or the Copyright Clearance Center at 978 750 8400 Please notify us immediately if you have received an unauthorized copy For edi torial comments or questions call 781 639 1872 or fax 781 639 7857 For renewal or subscription information call customer service at 800 650 6787 fax 800 639 8511 or email customerservice hcpro com Visit our website at www hepro com Occasionally we make our subscriber list available to selected companies vendors If you do not wish to be included on this mailing list please write to the marketing department at the address above Opinions expressed are not necessarily those of PPSA Mention of products and services does not constitute endorsement Advice given is general and readers should consult professional counsel for specific legal ethical or clinical questions 2012 HCPro Inc For permission to reproduce part or all of this newsletter for external distribu executive vice president of reimbursement for Paramount Health Care Company in Garden Ridge Texas With only a small increase to Medicare payments SNFs may be tempted to find more revenue with RUGs particularly involving therapy but they should be very cautious in how those services are billed Foster says In fact man
27. o have an actual coder who is more edu cated in the system one who can be more accurate she says But I m fearful that it is all going to fall to the MDS coordinators Examine internal processes Long term care facilities in particular should also focus on their pro cess for changing a resident s diagnosis Mines says The specificity of ICD 10 coding will allow for more timely adjustments as new issues arise or an existing diagnosis is resolved For example residents often come into a long term care facility after having sur gery for a fractured hip in the hospital Even though it has been resolved their diagnosis still reads 2012 HCPro Inc fractured hip A similar situation arises with pres sure ulcers as they progress or regress to higher or lower stages Facilities need to develop written poli cies that dictate an effective flow of information to input diagnostic changes as they arise This includes new diagnoses as they come up Mines says The billers need to have a point person who is knowl edgeable that they can consult with in updating changing and eliminating diagnoses and conditions The same diagnoses from the hospital stay should not continue from 10 years earlier if they are resolved Start sooner rather than later Pushing the ICD 10 back to 2014 shouldn t translate to an extra year of procrastination Duchek says Facilities should be using this additional time to
28. repare A Continuing Education Learning Objectives After reading this article you will be able to gt State the new compliance deadline for ICD 10 as established by HHS gt Discuss the reasons why HHS initiated a proposal for the ICD 10 compliance deadline delay gt Describe steps that facilities should take to prepare and implement a successful ICD 10 transition In April the U S Department of Health and Human Services HHS proposed an extension of the ICD 10 deadline for one year from October 1 2013 to October 1 2014 On August 24 HHS issued the final ruling confirming the one year extension which was instituted to allow more time for healthcare facilities particularly smaller facilities to adopt the new coding system We believe the change in the compliance date for ICD 10 gives covered health care providers and other covered entities more time to prepare and fully test their systems to ensure a smooth and coordinated transition by all covered entities HHS said in the final published ruling Many facilities expressed concern with the 2013 deadline pointing to the difficulty a variety of organiza tions had in meeting the compliance deadline for the Associated Standard Committee s X12 Version 5010 standards which updated billing software and laid the groundwork to accommodate the longer and more de tailed ICD 10 coding system In December 2011 CMS conducted a survey among 404 healthcare provi
29. s written by Diane L Brown BA CPRA To submit a question for upcoming issues email Associate Editor Melissa D Amico at mdamico hcpro com lama little confused on the significant change criteria and need some clarification In MDS 2 0 the division of changes was 0 1 2 to a 3 4 and vice versa Now with MDS 3 0 the division of changes is not clear know that it is always the team s decision if the residents have changed enough to impact their need for care but has there been an ADL division Doing a significant change for someone who goes from a 0 to 1 when even we can fluctuate in a day seems redundant Any clarification will be greatly appreciated 4 Improvement or decline in two or more areas such as decision making or ADLs are guidelines for your team to use to evaluate a situation rather than a mandate to always code these situations as a significant change More important for you and your team is to determine the impact of such changes on the resident s condition In Chapter 2 of the MDS 3 0 User s Manual there are sev eral pages and many examples of what may constitute a significant change of condition A significant change in status assessment SCSA is not mandated just because ADLs improve or decline SCSA decisions are not based on concrete criteria but more broad based criteria Guidelines for when a change in resident status is not significant include this is not an exhaustive list gt Instances in which t
30. sletter for external distribution or use in educational packets contact the Copyright Clearance Center at www copyright com or 978 750 8400 Page 10 PPS Alert for Long Term Care October 2012 MDS professor Test your knowledge of the MDS and long term care 5 A facility has only 30 days to respond to an ADR or by answering the following questions an automatic denial will occur a True 1 When billing for pneumovac and or influenza b False vaccines which of the following revenue code s should appear on the claim 6 Mrs Anderson requires an indwelling Foley catheter a 771 administration due to urinary retention Her physician has ordered b 636 vaccine a silicone coated catheter a bedside drainage bag an c 771 and 636 insertion tray and irrigations of normal saline every d 250 pharmacy day Which of these items will not be covered accord ing to the medical policy for urological supplies 2 Which of the following statements regarding Durable a Silicone coated Foley catheter Medical Equipment Regional Carriers DMERC bill b Bedside drainage bag nad c Insertion tray ing is not true d 0 F igati i sali a DMERGs are divided into four regions a i b Only a DMERC can be billed for parenteral and 7 Mrs Anderson also requires dressings to both of her enteral nutrition PEN and prosthetic and orthot q 8 hips The dressing to the right hip is Duoderm and is ic supplies for a reddened ar
31. ugh partnerships with the U S Department of Health and Human Ser vices Quality Improvement Organizations and state survey agencies gt Advance quality through innovation and demon stration with projects such as the Nursing Home Value Based Purchasing Demonstration which 2012 HCPro Inc attempts to prevent costly rehospitalizations through high quality care Aside from these direct objectives the 2012 plan gives nursing homes and SNFs a broad idea as to what CMS surveyors will be focusing on and the direction they should take their facility to maximize their reimbursement Quality matters Quality care and performance has been and continues to be a recurring theme which means facilities should continue to pay particular attention to the quality mea sures released by CMS says Janet Potter CPA MAS manager of healthcare research at FR amp R Healthcare Consulting Inc in Deerfield Ill Long term care facilities have had the stigma of Document resident care with ease Long Term Care Clinical Assessment and Documentation Cheat Sheets is the ultimate blueprint for how to provide resident centered care for any symptom or condition Available on CD this electronic only resource provides nurses with a thorough list of what to check and what to document during every shift based on the specific circumstances of a given resident Best of all the new electronic format of this content enables long term
32. up to speed in the coming years they will be swallowed up by the larger corporations Bufford says A lot of the national players already have quality trackers and they have the touch panels in the hallway For permission to reproduce part or all of this newsletter for external distribution or use in educational packets contact the Copyright Clearance Center at www copyright com or 978 750 8400 October 2012 PPS Alert for Long Term Care Page 9 where they can document the provisions of care to the residents he says They are ahead of the curve because they are going to be able to approximate what CMS is going to look at and you can track that yourself Instead of waiting for CMS to analyze your data and then give you back a score you re going to be able to respond immediately and see what needs to be improved Improving the survey process CMS recognizes that there needs to be more consis tency with the way surveys are conducted nationally so you can expect surveyors to come in with a much more defined role with a focus on key areas More than ever nursing facilities must be ready for survey at any time Potter says In this industry we ve always lived with the knowledge that surveyors could walk in at any moment With more and more potential things to be reviewed and scrutinized it is essential that facilities be proactive and prepared Everyone in the building from the director of nursin
33. y elderly patients may be too ill to do therapy especially when they are first admitted to a SNE and their care plan needs to reflect that That has always been the concern of therapists Foster says Our residents are sicker than they have ever been and the idea of taking someone who is 80 years old with a fractured hip to therapy especially if they also have diabetes or congestive heart failure or de mentia taking them to therapy with the idea of getting a very high or ultra high RUG is just not realistic Instead SNFs should focus their attention on provid ing a complete and individualized care plan For exam ple a younger patient who has just had a knee replace ment and is only going to be in the facility for two to three weeks should receive as much therapy as possible An older patient with multiple health issues may require less therapy or more focused therapy What you really need to work on is that you re providing the type of care that the residents need and also that you are reimbursed for the care that you re providing Hopp says In many SNFs there is a struggle between the pa tient s schedule and the therapist s schedule Therapists want to start at 8 a m but patients often want to sleep in take a shower and have breakfast before going to therapy With more focus on resident satisfaction says Questions Comments Ideas Contact Associate Editor Melissa D Amico Telephone
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