Take CARE with Infection Control

With frequently updated guidance from federal and state agencies, we are continuously hearing the most current information on how to protect our residents from COVID-19 with best practice infection control. Keeping all members of the team informed of the most recent processes may appear to be a daunting task; however, with the uptick in COVID-19 cases in nursing homes and CMS administrator Seema Verma stating concern, it’s a great time to review how we can keep our residents, staff, and selves safe.

Reliant has created a 4-step approach to Take CARE with Infection Control:

When considering implementation, identify appropriate hand hygiene frequency, PPE based on type of precautions, and items and equipment that need routine cleaning and disinfection.  Be attentive to sequenced steps and processes for hand hygiene, donning and doffing PPE, and cleaning.  In order to ensure reliability, commit to self and peer accountability and implementing PPE peers using return demonstration. To monitor effectiveness of implementation, assess and adjust processes as necessary.

Download and review CMS’ latest Infection Control Survey Guidance (released 8/26/2020) as a guide.

By working together as an interdisciplinary team and holding each other accountable for best practice infection control practices, we can minimize the spread of COVID-19 within our facilities.  Practice extreme diligence and caution with infection control and prevention processes.

CLICK HERE for more information on Reliant’s Take CARE with Infection Control initiative.

MACs Resume Medical Review on a Post-Payment Basis

In the August 6, MLN, CMS announced Medicare Administrative Contractors (MACs) are resuming fee-for-service medical review activities. Beginning August 17, the MACs resumed with post-payment reviews of items/services provided before March 1, 2020. The Targeted Probe and Educate program (intensive education to assess provider compliance through up to three rounds of review) will restart later. The MACs will continue to offer detailed review decisions and education as appropriate.

CLICK HERE to review the MLN Connects newsletter.


Although medical review has not been initiated at this time for dates of service during the public health emergency, future RAC and MAC reviews are forthcoming. According to an article posted on RAC Monitor on 8/25/20, high priority audits may include claims with

  • Positive COVID-19 diagnoses to ensure testing results are accurately documented. 
  • Remote patient monitoring codes

Providers should be reviewing claims and supportive documentation now to identify potential areas of improvement.

Additionally, the introduction of remote audits is anticipated. The remote audits allow for the current work-from-home, travel-restricted business climate.

CLICK HERE to view the article in its entirety.

What’s GG Got to Do With It?

Despite the many adaptations and additional considerations that have been adopted in the battle against COVID-19, healthcare providers in skilled nursing facilities (SNFs) maintain their primary focus of quality patient rehabilitation and care. In the midst of planning and delivering care in a pandemic, some may ask, Does data collection really matter right now?  What’s GG got to do with it? The answers are Yes and everything!

CMS has indicated the value of data collection of our patient’s functional abilities (i.e. Section GG) by signaling it as a key comparison of quality across post-acute settings, an indicator of resource use impacting reimbursement, and critical to guiding patient-centered care planning. Although CMS stated exceptions and extensions were granted because data collection may be greatly impacted by the response to COVID-19, beginning July 1, SNFs are expected to report their quality data to meet the SNF QRP requirements for the third quarter of 2020. (Download CMS’ SNF QRP Tip Sheet)

Knowing this data eventually will be publicly posted, the question now becomes Does it reflect our exhausting efforts to deliver care during this public health emergency? That answer is yet to be determined, but it is never too late for a review and refresh of Section GG content as well as considerations for coding and patient identification in the current environment.

Accuracy of Section GG coding depends not only upon the healthcare professional’s familiarity with the objective scales, but also with each item’s definition, intent and parameters for coding. For example, walking items may be completed within separate sessions. A single walking item may include a brief rest, as long as the resident does not sit down. These considerations may assist in completing a thorough assessment in isolation. CMS provides training videos on the SNF QRP Training webpage for instructional purposes.

Facilities can use Section GG data to capture potential changes in function that may require skilled intervention by completing interim assessments. It is the role of the interdisciplinary team to identify potential impacts of isolation on a patient’s biopsychosocial wellbeing and intervene as appropriate.

Finally, review the submission requirements for the SNF-QRP, so a technicality does not overshadow the successful outcomes your teams are creating. Avoid dashes, utilize the activity not attempted codes as necessary, incorporate at least one goal into the patient’s care plan and submit the completed data for at least 80% of your Medicare A claims.

The interdisciplinary team should champion the role of data collection, even in a pandemic, to ensure that we are facilitating the appropriate plan of care, capturing the true picture of the resident’s needs and maintaining the highest quality of rehabilitation and care. Our patients are counting on us!

Medical Review Audits Suspended

Reliant has worked closely with the National Association for the Support of Long Term Care (NASL) to raise awareness of the activity associated with Medicare’s medical review process during this pandemic, including pre-pay targeted probe and educate (TPE) activity and post-pay recovery audit contractor (RAC) reviews. At this time, Novitas, First Coast and CGS have suspended TPE activity until further notice. Our contacts indicate current pre-pay TPEs will be released and paid in the coming weeks.

According to an FAQ released on 3/30/2020, CMS indicates suspension of most Medicare Fee-For-Service (FFS) medical reviews during the emergency period due to the COVID-19 pandemic. The FAQ states that both pre-payment medical reviews such as the reviews for TPE and post-payment reviews conducted by the MACs, Supplemental Medical Review Contractors (SMRCs) and Recovery Audit Contractors (RACs) are suspended for the duration of the Public Health Emergency (PHE).

The FAQ also notes that “no additional documentation requests will be issued for the duration of the PHE for the COVID-19 pandemic.” Current post-payment review by the MACs, SMRCs, and RACs will be suspended and released from review as well. CMS is suspending these medical review activities for the duration of the PHE, but could conduct medical reviews “during or after the PHE if there is an indication of potential fraud.”

PPE Guidance from CDC and CMS

The CDC issued guidance for optimizing the PPE supply, specifically facemasks, gowns and eye protection, including suggestions on what to do in case of shortages.

CMS recommends reaching out to a health care coalition (HCC) in your area for emergency response assistance. Click here for an interactive map with contact information.

Additionally, AHCA has warned providers to beware of COVID-19 scams selling PPE or other supplies. To aid in differentiation between legitimate businesses and scams, the Federal Trade Commission (FTC) has provided general guidance on COVID-19-related scams.

March Clinical Appeals

Denial Reason Code W7020- NCCI Edit Update

In February, CMS rescinded the National Correct Coding Initiative (NCCI) Edits which restricted the billing of CPT codes 97530 and 97150 on the same day as billing of PT/OT evaluation codes (97161, 97162, 97163, 97164, 97165, 97166) retroactively to January 1, 2020. Nonetheless, many providers have experienced line item denials due to the edit enacted for the short duration. These line item denials are reflected by reason code W7020. To resolve, CMS will be correcting the NCCI edit, beginning April 6, 2020. Medicare Administrative Contractors (MACs) will automatically reprocess claims, without provider action.  When reconciling payments,

  • Review Part B line items for denial of HCPCs 97530 and 97150, in the presence of evaluation codes 97161, 97162, 97163, 97164, 97165, 97166.
  • If line item denials are identified, determine if reason code W7070 is appended.
  • If confirmed, flag impacted claims for review for automatic reprocessing following CMS correction of the edit, beginning April 6, 2020.
  • CMS has indicated provider action is not required.
  • Follow up with your MAC should reprocessing not occur or occur with errors.

SNF Claims Incorrectly Cancelled

From January 26 through February 16, 2020, a software issue caused SNF claims to be incorrectly cancelled with a message that there was no three-day qualifying hospital stay. This issue has been corrected. If your claims were incorrectly cancelled, re-bill them in sequential order to receive payment.

  • Claims need to process in date of service order for each stay for the Variable Per Diem (VPD) to calculate correctly.
  • Submit claims in sequence and wait at least 2 weeks before billing subsequent claims.
  • Some of the affected claims with older dates of service will require a timely filing exception; enter “Resubmission due to non-qualifying stay” in the remarks field.

Click here for more information.

The Amplifying Quality of Group Therapy

Although the concept of group therapy is not new to long-term care, the implementation of the Patient Driven Payment Model (PDPM) has ignited renewed interest in its utilization during a skilled stay. From the resource availability to expand restorative nursing programs that allow up to four skilled residents in a group, to the revised group definition under Section O of the RAI manual, it is highly likely the clinician, staff, and patient interaction throughout a stay will reflect an exciting environment of peer motivation and social engagement.  

Prior to PDPM, if a therapy clinician executed a group with skilled residents participating, the group had to be planned for no more nor less than four individuals. Now, when a skilled resident is included in a group, the clinician has the autonomy to mold the size of the group to include anywhere from two to six participants, as appropriate. The psycho-social benefits and opportunity to apply functional carryover techniques within a quality, patient-centered group have not changed.

As noted by CMS and in multiple research studies, the psycho-social benefits of group are varied and include enhanced learning, increased sense of support, decreased depression, and improved motivation. Consider the story of a skilled patient who planned to return home alone. Prior to the event that led to the skilled stay, she participated in social outings once a week and depended heavily on loved ones to drop by for social interaction. Her family and friends encouraged her to “get out more”, but due to a self-perceived burden and a touch of embarrassment over her functional changes, she frequently declined the invitations. Eventually, this unintentional social isolation led to depression, sadness, and declining functional health. In her weakened functional state, she fell and although no fractures or breaks resulted, she did admit to the hospital due to altered mental status, dehydration, and mild malnutrition. Once stabilized, she admitted to a skilled nursing facility with the hope her weakened state could be reasonably reversed for a safe return home. During her stay, she participated in a physical therapy group once a week in addition to her daily individual therapy. Knowing her history, the clinician formulated a peer group identifying patients with similar goals targeting gait and balance, with the knowledge that this patient needed the peer motivation and example for attaining and maintaining her functional gains once she discharged home. During those sessions, the patient was encouraged by the evidence that her story was not unique and allowed her to self-identify the functional and emotional effects of isolation all while achieving her physical therapy goals.

Group therapy presents the unique opportunity for the therapy practitioner or restorative nursing staff to engage the patient during their care journey in novel ways. As a result, success is often amplified due to the underlying qualities inherent within group formats that simply cannot be mirrored in individual treatment sessions.  Whether delivered by restorative aides as part of a nursing program or by therapy clinicians as part of a rehabilitation stay, there is magic in the makeup of a group that is created with patient-centered intention and guided by staff who recognize the benefits of community and teamwork.

Celebrating the Successes of 2019

The past year ushered in a new era for the long-term care industry. With implementation of the Patient Driven Payment Model (PDPM), as well as full implementation of the Requirements of Participation (RoP), evolving became a part of our daily lives.

Through preparation, collaboration and continued evaluation of processes we have celebrated many successes. Together over the past year, we have explored all aspects of the PDPM, as well as the regulatory impact of the RoP and rehabilitation’s role in partnering with facilities for collaborative communication and success, all while never losing focus on patient outcomes.

We celebrated patients’ successes as they met their goals and returned to prior levels of independence, many returning to the community. In 2019, Reliant therapists climbed our Clinical Advancement Ladder and teams continuously practiced at the top of their licenses all while commemorating holidays with themed parties, fabulous costumes and fun activities for the patients.

Because our dominant focus was on our care for the patient, we maneuvered through these uncharted regulatory waters successfully. As we continue to fine tune processes, our focus remains on patient satisfaction and positive patient outcomes for that is at the heart of all we do. Their successes are our successes!

A year from now when we are reviewing our successes, we will have learned, adjusted, grown and flourished. We look forward to our continued partnerships allowing us to do what we do best because, together, our Care Matters.

THE CLIENT CONNECTION: A COLLABORATIVE APPROACH TO QUALITY OUTCOMES

Every month on the third Thursday, Reliant’s Clinical Services offers a webinar to our partners on relevant topics within our industry.
January’s training An Overview of PDPM provided participants with the big picture of PDPM. In the coming months, we will be offering “deep dives” into various components of PDPM.
Join us in February to brush up on the long term care survey process and requirements of participation:Survey Preparedness: Ready, Set, Go! 

Year in Review: Client Connection

Reliant offers education opportunities monthly. Each topic is selected based on your feedback, regulatory changes, and industry trends. 2019’s schedule will be packed with information you don’t want to miss! Below are topics from 2018; let your Regional Director of Operations know if you missed one of these training sessions, and you’d like to know more!

  • Survey Preparedness
  • Therapy Cap Update
  • Discharge Planning: What’s Next?
  • Clinical Appeals Portal Demo
  • CMS Updates: SNF Proposed Rule
  • Fall Prevention: Tips to Make Your “Fall” Numbers Fall
  • 2018 MDS Updates: Section GG
  • Reducing Rehospitalizations Using S.O.S.
  • Partnering for Outcomes Using Reliant’s Model 10 2.0
  • Compliance Department Overview
  • Ringing in the New Year with Resolutions for Regulatory Success

No Patient Left Behind

No Patient Left Behind (NPLB) trains our therapists in interpretation of quality indicator reports and the impact of quality measure reporting to aid in the care of facility residents. This month we’ll look a little closer at the final element: Being an Advocate.

Reliant believes it is our moral imperative to do right by our patients and ensure dignity, quality, and the highest level of independence possible. Each care partner plays a role in the resident’s success and it’s important to remember, you don’t have to go to Washington to be an effective advocate for your patients. Advocacy starts at the facility level and means you’ll be the voice for the resident who can’t speak, the movement for the resident who isn’t independently mobile, or the reliable provider for the resident who needs reassurance.

From admission to discharge, your actions are contagious and by advocating for your patients through simple acts, others will want to be a part of that passion. There is purpose in what you do, never forget that!

No Patient Left Behind

No Patient Left Behind (NPLB) trains our therapists in interpretation of quality indicator reports and the impact of quality measure reporting to aid in the care of facility residents. This month we’ll look a little closer at the third element: Linking Quality and Care.

Reliant believes in equipping our therapists with the knowledge and resources to address quality measures and changes in resident function timely. NPLB describes the quality indicators identified by Medicare as critical to patient care and dives into the distinct role physical, occupational and speech therapy play for each.

National Rehabilitation Awareness Week 2018!

Last week Reliant Rehabilitation therapists celebrated National Rehabilitation Awareness Week. This year’s theme was “Move Better, Feel Better, Live Better.” Therapy departments from around the country submitted photos of their teams and shared stories of patient satisfaction and facility praises.

We are proud to partner with you for outstanding functional outcomes and patient care. Thank you for choosing Reliant Rehabilitation.