We need to reduce therapy utilization while maintaining high quality outcomes. Sounds daunting but it really is a mind-set, base your care and reimbursement on the resident versus the number of therapy minutes. Easy right? Not so much, it is a definite change of culture and focus and may take time to adjust. Here are a few quality measures CMS is currently using and will continue to use:
- SNF QRP
- Skilled Nursing Value Based Purchasing (SNF/VBP)
- Quality Measures/5 Star ratings
Other areas that will be monitored and/or trigger a red flag for CMS include:
- Therapy utilization changes with resulting declines in quality measures
- Decline in quality even without a change in therapy utilization
- Significant changes in comorbidity documentation
So what can we be doing now to prepare?
- Educate your team on the importance of performing a quality assessment on each and every resident. Capturing diagnoses and conditions for each resident timely is key to providing appropriate documentation on the MDS.
- Consider re-assessing residents and document all applicable comorbidities on the MDS prior to October 1, 2019. Remember, if a resident doesn’t have documented comorbidities on September 30 but suddenly does on October 1 it can send up a flag!
- Meet with your therapy provider and review the requirements under the PDPM model. The goal would be that consistent therapy services are provided. If a change in services will be planned, be sure that the documentation supports the reason for the change and that each resident continues to provide care as needed.
- Observe therapy services throughout the day. If group sessions are utilized, ask the therapist to show you the documentation to support this service is appropriate for each of the residents in the group now when maybe it wasn’t before October 1.
Although there aren’t any “proven” ways to transition to PDPM, these are a few areas that may flag CMS and result in audits we try to avoid.
Keep discussing the upcoming change with your team, develop a plan with your clinical team and QAPI and keep doing the right things for the right reasons and you will be fine!