Therapy Utilization: Getting it Right

Transcription

1 Therapy Utilization: Getting it Right Presented By: Cindy Krafft MS PT Director of Rehabilitation Consulting Services December 15, King Street, Suite 246 Northampton, MA Phone: Fax:

2 Instructions and Handouts for: Therapy Utilization: Getting it Right Eastern Standard Time 1:00 PM to 2:00 PM Central Standard Time 12:00 PM to 1:00 PM Mountain Standard Time 11:00 PM to 12:00 PM Pacific Standard Time 10:00 AM to 11:00 PM To participate in the webinar: 1. Dial (1) at least 10 minutes prior to the start of the webinar. 2. When asked, enter Conference ID #. 3. Give your agency s name. 4. At this time you will be entered into the call and in listen mode. 5. To view the visual part of this presentation, click on the link that was ed to you by GoToWebinar. 6. If at any time you need assistance you may press *0 for the operator. 7. There will be a Q & A period toward the end of the session. Questions will be answered in the order in which they are received. To ask a question, press *1. You will have the opportunity to ask your question and then be returned to Listen Only Mode. Do not press *1 prior to this time.

3 Speaker Introduction Cindy Krafft MS PT is the Director of Rehabilitation Consulting Services for Fazzi Associates, Inc. She has 15 years of home health experience ranging from PRN Clinician to the Director of Rehabilitation for a six agency home care system. She serves as the President of the Home Health Section of the American Physical Therapy Association, Chair of the NAHC Therapy Advisory Committee, and is on the NAHC Regulatory Affairs Committee. She has published a variety of articles in Caring Magazine, The Remington Report, Success in Home Care, Home Healthcare Nurse, and the Home Health Section of APTA newsletter. As well as being an expert on therapy practice in home care she also assists agencies with achieving OASIS competency. She served as the Clinical Co-Director of the Delta National OASIS-C Best Practices Project and currently acts as the Clinical Director of the Delta Excellence in Therapy Project. She is a well received speaker at both the state and national levels on the topics of OASIS, therapy documentation, program development, therapy utilization, and recruitment.

4 Therapy Utilization: Getting it Right Cindy Krafft PT, MS Director of Rehabilitation Consulting Services Therapy and PPS CMS attempted models could not predict therapy use Concerns that providers would skimp on high cost services such as therapy under a PPS model Intent to ensure services were not under provided 10 visit threshold: Changing Visit Patterns 50% of high therapy ended between 10 and 13 visits Tiered model: 26% increase in episodes with 14 or more Fazzi Associates, Inc. 1

5 Incentive? Example 1 Example 2 M02200 = 19 Actual = 14 M02200 = 19 Actual = 19 Revenue = $2337 ($663 lower) Revenue = $3000 Cost $126 X 14 = $1764 Cost $126 X 19 = $2394 Margin = $573 Margin = $606 0 to % increase Therapy in to % decrease 20 or more 5% decrease Determining Impact Using OCS Data in HHL article October 17, 2011 Number of Therapy Visits Percentage of Cases Ave Payment Per Episode in 2009 Change in 2012 Change in Rate % $ % +$ % $ % $ % $6817 5% $341 Fazzi Associates, Inc. 2

6 Loss or Gain? Number of Therapy Visits Payment in 2009 Payment in $1,460,498 $1,515, $360,282 $351, $433,105 $420, episodes Total: $2,263,885 Total: $2,287,792 + $23,907!! Who Decides? We believe that rehabilitation professionals, by virtue of their education and experience, are typically able to determine when a functional impairment could reasonably be expected to improve spontaneously as the patient gradually resumes normal activities. We expect rehabilitation professionals to be able to recognize when their skills are appropriate to promote recovery. Therapy Assistants Initial G Code analysis shows higher than anticipated use of therapy assistants. NOT a clinical i l issue. Focus is COST. Fazzi Associates, Inc. 3

7 Therapy Reassessments Audit results showing some issues with completion in the correct time frames. Larger issues with ihcontent NOT meeting the standard to support continuing therapy. Evaluation vs. Reassessment Evaluation of the patient for the purposes of forming a diagnosis and plan of treatment. Reassessment focuses on the plan of care using relevant patient information. Every 30 Days Minimally : Starts with the first visit from therapy Continues until discharge May cross certification periods DON T wait until the last minute Fazzi Associates, Inc. 4

8 Counting Visits 13 (before 14) Single Therapy: On literal 13 th Rural exception Completion resets 30 days Specific to each cert period Multiple Therapy: Close to No Ranges Completion resets 30 days Specific to each cert period 19 (before 20) Single Therapy: On literal 19 th Rural exception Completion resets 30 days Specific to each cert period Multiple Therapy: Close to No Ranges Completion resets 30 days Specific to each cert period Reassessment Documentation Clinically supported statement of expectation that the patient can continue to progress or resume progress after plateau or regression. Speak to the effectiveness of therapy in relation to the goals. Plans to continue or discontinue: Refer to clinical findings (objective assessments) and treatment plan revisions. Do We Withhold? In order to hold any therapy service, a physician order would be required. Reason for hold would have to be clinically or patient driven. If skilled services are necessary and orders are in place, withholding opens agency to legal action for not providing care. Fazzi Associates, Inc. 5

9 Take a Deep Breath How many patients have therapy for more than 30 days? How many of your patients actually end up with 14+ visits? Of those, how many are multiple therapy? Missed Reassessments Error rate anticipated to be higher in first few months since April 1. Agency clarity around missed definition: Cancelled Visits Scheduling Changes Patient Driven Exceptions Patient Driven Exceptions Missed Visits? Single Therapy Multiple Therapy Interruptions in Care? Hospitalization SNF Who caused the missed reassessment?? Fazzi Associates, Inc. 6

10 CMS and 13/19 When reassessment requirements are not met by visits 13 and 19, non coverage will apply to visits starting on 14 and 20 (respectively) and continuing up to and including the visit during which required reassessments were conducted. Coverage resumes on the visit after the final reassessment visit for each respective therapy threshold. Example: OT the Active Therapy 13 th visit done by COTA 15 th visit done by OT with reassessment At risk Visits 14 and 15 CMS and 30 Days A similar policy applies when therapists fail to reassess a patient by the 30 th day with resumption of coverage on the visit iitafter the visit on which the required reassessment is conducted. Fazzi Associates, Inc. 7

11 Semantics Is a missed therapy reassessment. Non Billable Non Covered Doesn t Matter Non Billable Speaks to skill level seen on the visit Used to account for time spent with a patient that cannot be billed for: Second therapist in the home for purposes of helping to lift a patient Therapist AND Assistant out in the home at the same time Patient not home or refused visit upon arrival Non Covered According to CMS: No visits should be omitted. The visits that are not payable should be reported with non covered charges and will be assigned provider liability. Reporting non covered charges is required per the Claims Processing Manual, Chapter 10, Section Fazzi Associates, Inc. 8

12 never been great... CMS pointed out that non covered charge information submitted by home health agencies has never been great. Their intent has been for home health agencies to include all non covered visits and charges on claims to ensure a better representation of all home health costs. Furthermore, reporting non covered charges shouldn t be limited to missed therapy reassessments. Home health agencies should include all non covered visits and charges on their claims, such as nursing assessments, aide supervisory visits, etc. How to Bill According to the National Uniform Billing Committee coding guidance, form locator 48, Non Covered Charges is a required data element for Medicare. The Medicare Claims Processing Manual, Chapter 10, Section 40.2 instruction at: 4c10.pdf Billing Systems Need to confirm that the missed assessment information is correct BEFORE the claim goes out the door. Fazzi Associates, Inc. 9

13 Error Rate Trending Missing reassessments should be drilled down to determine patterns and decrease errors: Process System Discipline Clinician Counting Visits Not Covered = Not Counted Example 1 Multiple Therapy (PT and OT) 22 visits Close to 13, OT is compliant BUT PT is not. 10, 11, 12, 13, 14, 15, 16, 17, 18,19,20 10, 11, 12, 13, 14, 15, 16, 14, 15,16,17 Paid for 19 visits regardless Fazzi Associates, Inc. 10

14 Example 2 Single Therapy PT for 17 visits 10, 11, 12, 13, 14, 15, 16, 17 10, 11, 12, 13, 14, 15, 14, 15 Paid for 15 regardless Example 3 Single Therapy PT for 17 visits (30 day) 7, 8 (day 30), 9, 10, 11, 12, 13, 14, 15, 16, 17 7, 8 (day 30), 9, 9, 10, 11, 12, 13, 14, 15, 16 RURAL Still OK 7, 8 (day 30), 9, 9, 10, 11, 12, 13, 14, 15, 16 URBAN bigger issue Contact Information Website E Mail ckrafft@fazzi.com Twitter Account FazziRehab Fazzi Associates, Inc. 11