Regan Mclaughlin, OT and Caitlyn Boldt, SLP of Reliant Rehabilitation share Virginia Rannebarger’s journey from stroke to home. Partnering with our facilities for the success of our patients is our passion! Congratulations Virginia, it was a pleasure to be a part of your journey. We know you are enjoying being home and “crafting” again.
Every year in late winter, the President releases a proposed budget request. The President’s Proposed Budget is a blueprint for the upcoming federal fiscal year (FY) containing an array of provisions which may or may not be implemented. Read on for a list of the provisions and proposals.
Last November, CMS issued a Temporary moratorium on imposing certain enforcement remedies for specific Phase 2 requirements. It was advised that this 18 month moratorium on the imposition of certain enforcement remedies be used to educate facilities about specific new Phase 2 standards.
• The following F-Tags included in this moratorium are:
• F655 (Baseline Care Plan); §483.21(a)(1)-(a)(3)
• F740 (Behavioral Health Services); §483.40
• F741 (Sufficient/Competent Direct Care/Access Staff-Behavioral Health); §483.40(a)(1)- (a)(2)
• F758 (Psychotropic Medications) related to PRN Limitations §483.45(e)(3)-(e)(5)
• F838 (Facility Assessment); §483.70(e)
• F881 (Antibiotic Stewardship Program); §483.80(a)(3)
• F865 (QAPI Program and Plan) related to the development of the QAPI Plan; §483.75(a)(2) and,
• F926 (Smoking Policies). §483.90(i)(5) While this moratorium is still active, providers should have these requirements in place now. In the same memorandum, CMS revealed changes to Nursing Home Compare (NHC) relative to survey and health inspection.
• Freeze on Health Inspection Star Ratings: Following implementation of the new LTC survey process on November 28, 2017, CMS held constant the current health inspection star ratings on NHC for any surveys occurring between November 28, 2017 and November 27, 2018.
• Availability of Survey Findings: The Survey findings of facilities surveyed under the new LTC survey process would be published on NHC, but not incorporated into calculations for the Five-Star Quality Rating System for 12 months. Link to full memorandum.
Chart review of the 3 phases of implementation:
Phase 1: Implemented November 28, 2016 *indicates this section is partially implemented in Phase 2 and/or 3
• Resident Rights and Facility Responsibilities*
• Freedom from Abuse Neglect and Exploitation*
• Admission, Transfer and Discharge*
• Resident Assessment
• Comprehensive, Person-Centered Care Planning*
• Quality of Life • Quality of Care*
• Physician Services • Nursing Services*
• Pharmacy Services*
• Laboratory, radiology and other diagnostic services
• Dental Services*
• Food and Nutrition*
• Specialized Rehabilitation
• Administration (Facility Assessment- Phase 2)*
• Quality Assurance and Performance Improvement* – QAPI Plan
• Infection Control- Program*
• Physical Environment*
Phase 2: Implemented November 28, 2017
• Behavioral Health Services*
• Quality Assurance and Performance Improvement*- QAPI Plan
• Infection Control- Facility Assessment and Antibiotic Stewardship**
• Physical Environment- smoking policies*
Phase 3: Implementation November 28, 2019
• Quality Assurance and Performance Improvement*- Implementation of QAPI
• Comprehensive Person-Centered Care Plan: Trauma informed care
• Infection Control- Infection Control Preventionist*
• Compliance and Ethics Program*
• Physical Environment- Call lights at resident bedside*
• Training Requirements*
ICD-10 coding has never been so daunting! Thanks to search engine crosswalks and funny memes, the 2015 transition to ICD-10 did not leave any permanent scars, and most of us can now recall treatment codes with ease. However, ICD-10’s role in PDPM hasshuffled the deck. Suddenly, we are questioning our own knowledge and wondering if we have the skill set to be successful.
As we prepare for the transition to PDPM, it’s important to remember, we’re all in the same boat: ICD-10 coding on the MDS directly maps our patients into case mix categories for payment. There is no buffer between coding and reimbursement. CODING IS reimbursement for physical therapy, occupational therapy, speech language pathology, nursing and non-therapy ancillary. CMS says the primary patient diagnosis allows us to identify the patient’s unique conditions and goals which should be the primary driver for care planning and delivery of services.
Many facilities already have the ingredients for a recipe of success: a collaborative effort between nursing and therapy is key in identifying each active condition on admission and changes in condition throughout the episode of care. Let’s consider these additional idioms:
Don’t put all your eggs in one basket.
- Having a designated ICD-10 coder is an awesome resource; however, never discount the input from the other skilled professionals interacting with the patient. Coders provide accuracy, but clinicians, physicians, and dietitians provide the details to hone that accuracy.
The devil is in the details.
- If you’ve ever wondered whether each element on the MDS mattered, PDPM has given you the answer. The ICD-10 code entered in I0020B, the resident’s primary medical condition, will map case mix for physical, occupational, and speech therapy components. Beyond this, information entered into sections C, D, E, GG, H, I, J, K, M and O will contribute to classifying each resident, identifying conditions/comorbidities, and identifying the function score..
The ball is in your court.
- Begin to put systems in place to identify active conditions of the resident. Reliant therapists perform a full system evaluation, so engage their input for areas which may have been missed. During daily stand up or triple check, include clinical condition conversations to quickly identify changes which may need to be reflected in coding.
Strong partnerships for understanding and implementing processes for ICD-10 is critical. As stated, coding impacts PT, OT, SLP, Nursing, and Non-therapy ancillary case mix groups. Accurate coding ensures resource availability for successful outcomes and patient satisfaction. Just remember, Rome wasn’t built in a day, so let’s start conversations now.