By now, we’ve all heard about the numerous suits filed by the Department of Justice (like this one, this one, this one, and this one) accusing SNFs and their contract therapy providers of upcoding patients to the highest level of therapy without evaluating actual patient needs.
On this scariest of days (#Halloween17!) what other frightening things might your therapy provider be doing (or failing to do) that could be putting you at financial risk and/or losing money for your organization?
They’re adding sneaky hidden costs and charging alarmingly high rates!
Check the structure of your contract with your therapy provider to make sure that RUGs are paid at the same cost per minute. Unscrupulous therapy providers can add hidden, inflated costs by varying the cost per minute by RUG category. Also make sure that you are not paying for minutes in excess of the RUG or for activities that should be considered part of a normal day. And this may sound obvious, but if your therapy provider has been with you for many years, they could be charging you rates that were reasonable 5-10 years ago. However in today’s market, your rates per minute could be 8-10% less.
On the Part B side, be sure that your therapy provider is taking the Multiple Procedure Payment Reduction (MPPR) out of their invoice. These reductions apply when more than one unit of certain CPT codes are provided / billed on the same day, regardless of discipline. As Part A utilization decreases and Part B utilization increases, be sure that your therapy provider is taking MPPR out of their invoices. Otherwise, they may be taking 6-7% more away from your bottom line.
They’re experiencing unnerving issues with staffing coverage!
Staffing insufficiencies may mean that your therapy provider is not delivering appropriate minutes of therapy, covering weekend therapy needs, or ensuring that therapy is provided for patients with changes in condition. When staffing coverage is not adequate, RUG categories can be lowered or missed all together due to delays in initiating care or due to failure to provide therapy seven days per week. Look for an overuse of Change of Therapy (COT) Assessments. If your therapy provider is overusing the COT assessment, it could indicate that they may not be able to consistently provide staffing levels sufficiently to ensure necessary therapy is being delivered to your patients. This can result in decreased revenue and discontinuity of care. What’s more, if your facility’s usage of COT Assessments is significantly higher or lower than the national 80th percentile of 17.8%, it sends up a red flag and puts you at high risk for ADRs. Egad!
They’re suffering from a frightening inability to deal with complex medical diagnoses!
As the acuity of patients sent to SNFs increases, it is imperative that therapy providers have the expertise to deal with the complex medical diagnoses often associated with geriatric care. Does your therapy provider work collaboratively with your own team to design and implement clinical pathways for diagnoses (like CABG, stroke, Parkinson’s disease, diabetes, CHF, COPD, and pneumonia)? When a patient has a secondary diagnosis like dementia, does your therapy provider say, “Alas, there’s nothing we can do!”? Or do they employ a specialized dementia care program that can slow the progression of the disease, alleviate symptoms, and prolong independence?
They can’t defend against an onslaught of ADRs and ghastly pre-ray probes!
As we noted back in February, SNFs are getting bombarded by ADRs and reviewers (like Strategic Health Solutions, SCIO, and HDI) have no intention of easing up. Does your therapy provider have systematic processes in place to ensure that therapy documentation withstands reviewers’ scrutiny and audits are passed the first time? What is their method for dealing with denials? And how do they work with your SNF to manage pre-pay probes? Do they share in the risk with you?
Their lackluster therapy program is doing little to prevent hospital readmissions.
Readmissions impact your reimbursements, star-rating, and ability to attract patients. Research shows that a great therapy program lowers post-discharge hospital readmissions. Does your therapy provider provide training and recommendations for family caregivers? Do they do home safety assessments prior to discharge, suggest home modifications, and recommend assistive devices? Do they assess patients’ cognitive and physical abilities to manage medications (open containers, understand prescriptions)? Do they truly partner with your interdisciplinary team to minimize re-hospitalization risks?
Therapy Management, Inc. combines clinical and compliance expertise with care beyond compare for patients (as well as for our SNF partners). Clients tell us that we have uniquely specialized expertise to care for seniors, and we help ease the headaches, hassles, and risks associated with managing rehabilitative care. Our team is available to audit your current therapy program, evaluate your compliance plan, and provide recommendations. We look forward to speaking with you.
