In the OIG, Office of Inspector General’s semiannual report to congress, the OIG reported that “the Medicare Payment System for Skilled Nursing Facilities needs to be reevaluated”.
The OIG reports that “Medicare payments for therapy greatly exceeded SNFs’ costs for therapy. Combined with the current method of paying for therapy, this large difference between therapy payments and costs creates a strong financial incentive for SNFs to bill for higher levels of therapy than necessary. Under this system, SNFs increasingly billed for the highest level of therapy even though key beneficiary characteristics remained largely the same”.
You can read the entire report here.
On November 30th, 2015, Senior Counselor Andrew VanLandingham from the OIG reported during the RAC Monitor broadcast that the OIG has a high priority of Medicare items they’re focusing on, one being SNF compliance with PPS billing specifically the level of therapy intensity provided and the reasonableness and necessity of the therapy services provided.
Even though the New Year is just around the corner, the theme for SNFs isn’t changing. We are still and will be under a strenuous amount scrutiny to prove that the services we are providing are reasonable and necessary, require the skills of a therapist, and are vital to treat the resident’s diagnosis or condition. Not only is the burden of proof is not only on therapy but on the SNFs as well. Level of care and length of stay scrutiny weighs heavily on the SNF, which is also a focus by government agencies.
What’s a facility to do?
– Be proactive — conduct internal audits, and ensure you have an effective triple check process.
– Manage and validate successful Medicare/Utilization Review meetings.
– Always scrutinize your internal processes! Find issues internally, identify root cause analysis, and fix the problem.
– Continue to monitor and scrutinize your practices, and improve.
Solid documentation practices in all departments is absolutely crucial to support the care needs provided to our residents.
- Gina Tomcsik, Director of Compliance
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