Are You Ready for the Phase 2 November 28th Deadline?

If you are a skilled provider, you are actively thinking about November 28th.  It is most likely keeping you up at night. For those that are not in the loop, November 28th is the due date for Phase 2 completion of CMS’ new requirements for participation. If this is not something you’re taking seriously or actively working on well before November, you may want to keep reading.

RoP Summary

On October 4, 2016, CMS published in the Federal Register the final rule on the Requirements of Participation (RoP) that long-term care facilities must meet to participate in the Medicare and Medicaid programs. This rule represents the most comprehensive update to the RoP since the 1990’s. CMS explained that the changes to the requirements are needed keep pace with the changes in the industry and assist in the goal of improving the provision of health care and patient safety.

A major theme of the new requirements is person-centered care, with an emphasis of residents and their representatives being informed, involved, and having control. You will see examples of this person-centered emphasis in the care planning and discharge planning requirements. The facility assessment is integrated throughout multiple sections of the RoP. The purpose of the facility assessment is to ensure that facilities have sufficient number of staff who are competent to meet the needs of the population the facility serves and that facilities have appropriate resources to meet the needs of their population on a day-to-day basis and in emergency situations.

The RoP is effective in three phases:

  • Phase 1: CMS contends that these requirements are relatively straightforward to implement, and require minor changes to survey process. They were effective November 28, 2016.
  • Phase 2: Includes the requirements that CMS felt providers need more time to develop and will include a new survey process to assess compliance. These requirements are effective November 28, 2017.
  • Phase 3: These are the requirements that need more time to implement and may require personnel hiring and training and implementation of systems approaches to quality. Facilities must comply with these requirements by November 28, 2019.

The RoP is expansive and cannot be easily summarized. We expect that CMS will issue interpretive guidance to assist providers in complying with the new requirements.

Although CMS contends the Phase 1 Requirements are relatively straightforward to implement and require only minor changes to the survey process, providers need to review their policies and procedures and make revisions to ensure compliance.

Phase 1 included many obligations regarding admissions, transfer and discharges, care planning, the use of side rails, as well as many updates to resident rights, abuse procedures and definitions, grievance process requirements, and various other changes. It is imperative that facilities evaluate their current policies and procedures, facility postings, and admission process to ensure compliance with the Phase 1 requirements.

To prepare for the Phase 2 implementation date, which is mere months away, facilities should establish a Phase 2 work plan to accomplish the many tasks required for compliance. This will include:

  • Completing a facility assessment to ensure the facility has the appropriate resources and competent staff to meet the needs of its population.
  • Developing the written QAPI plan to present to surveys on the next annual survey.
  • Implementing an antibiotic stewardship program.
  • And many other changes in current processes which includes a 48-hour initial care plan.


Creating a sound QAPI program is one of the largest components of this task list. If you haven’t already, look for Lean Six Sigma and QCP (QAPI Certified Professional) certifications that may be offered through various state and national associations. CMS doesn’t specify which method is preferred, but encourages formalized process improvement training in order to implement at successful and integrated QAPI program.

In conclusion, the new requirements have very broad implications on facility operations and administration and facilities will need to allocate additional resources to ensure compliance.  We suggest developing a RoP Implementation Team that is focused on driving a RoP implementation work plan targeted at accomplishing required actions for each phase of implementation. Many of the changes will require updates to policies and procedures, new or revised training, comprehensive systems review, formal notices to residents, and impact daily care processes.


HTS is assisting our clients through this RoP process by partnering with Proactive Medical Review who offers a partnership plan for assisting clients through each phase of implementation.
This plan includes a facility-specific needs assessment and detailed implementation guidance, as well as:

  • Off-site policy and procedure review in each implementation area with redline suggestions for meeting the updated requirements. Policy templates will be provided as needed based on the policy/procedure gap analysis.
  • Implementation site visit and training options.
  • Access to our implementation checklists, timelines, and updated resident notices which meet RoP requirements, as well as training tools and resources.

It’s an “all hands on deck” world to meet the RoP Phase 2 deadline. We encourage you to act now by seeking proper education and forming your committees and to not wait until September to make this happen. November 28th will be here before you know it.


Guest Blog

Article co-written by:

Cassie Murray, OTR/L, QCP
Exec Director of Clinical Operations, Healthcare Therapy Services, Inc.
cmurray@htstherapy.com | 800-486-4449 ext 210

 

Shelly Mafia, MSN, MBA, NHA, QCP
Director of Regulatory Services, Proactive Medical Review
smaffia@proactivemedicalreview.com  |  812-471-7777

As many as one million people in the US are living with Parkinson’s disease (PD). Parkinson’s is a chronic and progressive movement disorder, meaning the symptoms continue and worsen over time. The average onset for all people with Parkinson’s is age 60 and although there is no cure for the disease, there are treatment options to help manage the symptoms.

Early Warning Signs
It’s important to recognize the early warning signs of PD. An early diagnosis may help slow the onset of the disease. Some of these symptoms are normal signs of aging. If you have more than one symptom or a symptom persists, talk with your doctor.

  • Tremor or Shaking
  • Dizziness or Fainting
  • Trouble Moving or Walking
  • Loss of Smell
  • Trouble Sleeping
  • Constipation
  • Soft or Low Voice
  • Change in Handwriting

 

How Can Therapy Help?
Taking advantage of the expertise of a team of professionals can be very beneficial for somebody living with Parkinson’s. In addition to a specialized neurologist, physical, occupational and speech therapy can effectively manage the symptoms and side effects of PD to maximize quality of life.

Physical Therapy
A Physical Therapist (PT) is trained to work with individuals to regain and maintain mobility. A PT can develop customized exercise programs to address balance problems, lack of coordination, fatigue, pain, gait, immobility, and weakness.

Occupational Therapy
Occupational Therapists (OT) can help modify your environment and daily activities in order to accommodate your changing needs. Occupational therapy focuses on helping you maintain your independence.

Speech Therapy
A Speech-language Pathologist (SLP) can help improve Parkinson’s disease speech problems and provide coping strategies for those who have trouble swallowing.

 

If you or a loved one has been diagnosed with Parkinson’s disease, talk with your doctor about the benefits of physical, occupational and speech therapy.


Source: Parkinson’s Disease Foundation

 

In today’s climate of scrutiny and burden of justifying therapy services and skilled stays, it is becoming increasingly critical for nursing to take charge in documenting each patients’ skilled needs. Specifically, what should the nurses be documenting in the medical record? How specific is the training for your nursing staff?

Before you answer, remember that the rules of documentation have changed greatly in the past 3 years. Even now, something that is the norm could likely be scrutinized in future audits. Whether you’ve had ADRs and denials for payment, it’s not a matter of if…but when. Those of us that are laser focused on the regs and changing climate of our industry know why things have altered so greatly. However, I have found that keeping to the basics is the best way to explain documentation expectations that are critical for justifying a skilled stay. I have also had my own documentation scrutinized, reviewed my fair share of ADRs and audited countless charts for congruent nursing and therapy documentation. The ideas below are a culmination of questions, mistakes, training and conversations by nurses, administrators and corporations. Try using these proven strategies to improve your skilled nursing documentation to support therapy services, and ultimately support the skilled stay:

The Do’s and Don’ts:

 

 

Justifying a Skilled Stay:

Nurses must ask themselves the following questions (and document the answers) each and every day:

  • Why is this patient here?
  • What is preventing this patient from going home right now? Could this patient go home right now and be safe and independent? Why not?
  • What are you doing that would not or could not happen for this patient at home?
  • Have you noticed this patient improving in any aspect of mobility? Self-care? Communication?
    *Even minor improvements need to be noticed and documented.
  • Why is this patient receiving PT, OT or ST?
  • What would/could happen if this patient was not an inpatient receiving care?
  • What are all of the medical complexities that are impacting this patient’s recovery. Explain the multiple conditions that you are managing. What is making this patient’s recovery take this amount of time?

 

RUG Supportive Documentation: Do they know the Why?

  • Do your nurses know what a RUG level is? Try asking several nurses on your rehab unit if they know what a RUG level is…you may be surprised by how many do not know. Do your nurses understand the importance of ADL coding?  Nurses need to understand the basic reimbursement system for the stay in order to understand the importance of the documentation. Provide a basic PPS inservice to help your staff understand how the MDS, nursing notes and therapy notes combined determine the RUG level. The medical record must make sense—nursing notes and therapy notes must support the coding on the MDS.
  • Do your nurses understand that PLOF is critical for establishing all goals? What was the patient doing prior to the hospitalization? Was he/she completely independent with all self-care and mobility? What about higher level tasks—grocery shopping, driving, cooking, laundry?
  • What does the patient need to be able to safely do prior to returning home? What impairments are preventing the patient from doing these things?
  • Are your nurses documenting their skilled nursing interventions? What if therapy services are denied? Will your nursing documentation prove a skilled nursing level? Provide nursing education regarding specific skilled nursing interventions. Provide sample documentation that reflects skilled nursing interventions.

I hope that these tips and questions help to gauge the level of training and direction for our SNF nurses. Now more than ever, you deserve to be paid for the great care you provide.

HTS is committed to the success of our clients and partners. That is why we provide on-going support and education for our therapists, nurses, and the entire IDT. With the changing expectations for justified skilled stays, make sure you are partnered with a dynamic, progressive therapy provider who will support and enhance your position in our post-acute care market.


Guest Blog

Cassie Murray, OTR, QCP, IASSC CYB 
Cassie Murray is the Executive Director of Clinical Services for Healthcare Therapy Services. A 1994 graduate from Indiana University in Occupational Therapy, Cassie has over 22 years of experience in long term care, hospital, outpatient and home health. She provides support for HTS therapists and partnering communities through program development, training on regulatory requirements and ongoing quality assurance. She is active in state and national associations such as Leading Age, AHCA, NASL, AOTA. Her passion for rehabilitative services is inspired from personal experience with her father suffering a stroke while Cassie was in high school. This led to her successful career path in occupational therapy.

To contact the author: cmurray@htstherapy.com | 800-486-4449 ext 210 | www.htstherapy.com

Summer is a great time to spend time with family and friends. The summer sun allows us to enjoy many outdoor activities. Barbecues, swimming, and trips to the beach make summer an exceptional time of year!

For aging adults, the summer months can also be hazardous to your health and heart. Problems like dehydration, sunburn, and exasperation of pre-existing conditions are common after too much exposure to the sun. For people with heart conditions, the heat can be a matter of life and death. It’s important to stay safe when the temperature rises!

 

Tips for Beating the Heat:

  • Stay Hydrated: Seniors are less likely to feel thirsty and dehydration can set in quickly. Be sure to drink the recommended 6 to 8 glasses of water a day.
  • Apply Sunscreen: Sunscreen takes time to work, so apply it prior to going outdoors. Reapply the sunscreen every two hours.
  • Dress for the Weather: Wear lightweight, breathable fabric such as cotton. Wide-brimmed hats can help protect from the sun.
  • Wear Protective Eyewear: Sunglasses can help reduce damage that could cause cataracts and age-related eye disease.
  • Stay Indoors During Peak Heat: The sun is most intense during the middle of the day (12pm to 3pm). Schedule your outdoor activities in the morning or evening when the weather is cooler.
  • Check Your Medications: Some medications can cause increased sensitivity to the sun. Look at the warning labels and talk to your doctor about concerns or questions you may have.

 

How Therapy Can Help
Heat is stressful on the cardiovascular system and can exasperate cardiopulmonary conditions making it more difficult to breathe. If you have heart and lung disease, you may benefit from Physical and Occupational therapy. Therapy can help individuals manage and minimize the debilitating effects of pulmonary and cardiac diseases by helping you control your symptoms and resume an active life within the limits of your condition. Talk to your doctor today about the benefits of therapy for your cardiopulmonary needs!

Are you making evaluation complexity coding too complex? Don’t make this more difficult than it is! Instead of trying to navigate all of the fancy terminology being used to educate us on how to correctly code complexity, let’s try looking at it plain and simple.

Here are some common problems that have already been discovered and tips for improvement (in plain language):

1. Clinical Decision Making
Clinical reasoning and decision making occurs throughout the evaluation as the clinician decides which questions to ask, what assessment tools and tests to use, identifying goals, deciding what modifications are necessary, etc. Keeping in mind all decisions being made through the course of the evaluation and documenting/justifying those decisions will provide support of the complexity chosen.

2. Patient History
Consider what you need to know about the patient’s medical history to make clinical decisions and develop a skilled POC. Be sure to clearly document all aspects of the patient’s history that you used to determine the plan and goals. Explain specifically how the patient’s medical history is impacting the current POC and your approaches to therapy intervention.

3. Occupational Profile
OT should document detailed description of the occupational profile. Use an Occupational Profile worksheet to assist. If you don’t already have a worksheet, create one for your OTs to help guide the narrative within the documentation. AOTA has provided an occupational profile template. Utilize the available tools from your associations and simply describe the areas within the evaluation.

4. Formal Tests
In order to accurately code the complexity of the evaluation, formal testing must be completed. Make frequently used tests readily available. With the new coding, it is necessary to go ahead and complete at least one formal test on day 1 with the initial evaluation and summarize the results within the POC. This is another component to accurately coding the complexity of the evaluation. Be sure to update the results of the selected tests at re-cert and DC as well.

5. All Criteria Required
Remember that you must code “down” if all criteria for the complexity level is not met. All criteria must be met (and documented) for each complexity level.

Keep in mind that the evaluation is still the same evaluation! Consider that by coding the complexity level, this is really just a way to ensure that we are documenting more thoroughly and justifying our services. I think that often we take for granted the skill and sophistication that we provide. Document your thinking process as you are creating the plan for your patients. No one else is able to do what you do!


Guest Blog

Cassie Murray, OTR, IASSYC CYB 
Cassie Murray is the Executive Director of Clinical Services for Healthcare Therapy Services. A 1994 graduate from Indiana University in Occupational Therapy, Cassie has over 22 years of experience in long term care, hospital, outpatient and home health. She provides support for HTS therapists and partnering communities through program development, training on regulatory requirements and ongoing quality assurance. She is active in state and national associations such as Leading Age, AHCA, NASL, AOTA. Her passion for rehabilitative services is inspired from personal experience with her father suffering a stroke while Cassie was in high school. This lead to her successful career path in occupational therapy.

To contact the author: cmurray@htstherapy.com | 800-486-4449 ext 210 | www.htstherapy.com

 

How Would You Rate Your Rehab Department?

If your answer isn’t a solid 4-Star or better, it might be time for a long discussion, or possibly a change or overhaul of how your services in your rehab department are being delivered.  If you can’t give them at least the high school equivalent of a B+, you’ve got some valid issues to discuss and work to be done.

Amidst the enormity of never ending and changing federal and state policies, issues, mandates and initiatives that affect our long-term care industry, we must begin to expect our partners (a.k.a. our vendors, business associates and internal departments) to accept a portion of the burden and help our SNF facilities move forward.

I’ve spent the last 26 years working both directly for SNF’s and other providers, as well as the last sixteen years in contract rehab, auditing and risk management. I have seen a lot of great…and not so great therapy departments. I have assisted in cleaning up a fair amount of therapy programs, and I’d like to share just a few pointers on what to look for, and how to begin.  In essence, what qualities or attributes should you look for?

I’m sorry, but fancy equipment, lovable therapists, low rates and glossy sales binders simply don’t make the difference between success and mediocracy these days. I hear it all the time. Let me share a verbatim statement from one of my old cases.

“Oh, we just really love Ruth Ann, our therapy manager.  She is just wonderful.  I don’t get any reports or hear anything from the corporate office, but I love our therapy team.”

Not. Good. Enough.

It’s 2017 people!  7 days a week is a standard expectation.  Therapy managers in the morning meeting and care plans should be a given. Competent therapists that are skilled in the treatment of older adults is a no-brainer. This is basic stuff. What I am asking you to do is dig deeper. Look at the systems, look at the foundation of this partner. What have they done for you lately? And what are they doing for you tomorrow to compliment the objective and vision for the future of your building?

Here is what your therapy provider should be doing for you…

  • Complete transparency as a Partner; if a reimbursement changes, address it then so you aren’t on the losing end, such as in Managed Care contracts.
  • Case mix support. They should know your state’s system, and identify routes to help improve and maintain this.
  • Extensive programming and protocols, especially for those diagnosis most prominent in your mix.
  • Full auditing services (and not by someone with a vested stake for it to look “good”).
  • Complete ADR and Denial support.
  • Marketing, and not just talking about it, but doing it.
  • Tracking and reporting your Outcomes. Value based is coming, it’s time to be prepared.
  • Provide you with hospital reports for your feeder hospitals, including re-hospitalization numbers.
  • QM and QAPI active participants.
  • NOT turn a blind eye on your behavioral and dementia patients. They have needs, too, and the therapists should be trained on programming and techniques.
  • PUF analysis and a plan of correction if they are putting you at risk.
  • PBJ uploads.
  • Management of the Program and Staff! If that Regional or Manager above the building level isn’t there regularly, there is an issue.  Not everything can be seen, completed or corrected remotely.

A culture of stewardship and servitude involving real people that are  true partners that exhibit  forward thinking, progressive and strategic ideas and with the momentum for actual implementation, are the cornerstones that effectively help drive SNF providers forward and upward in service and success . This success is triggered and facilitated by not only your internal team but also your vendors, especially rehab. These areas are what can truly, ultimately make the difference between being a 3-star building and a 5-star building.  It determines being financially viable or struggling with odious and resource-draining factors such as audits, tags and/or reduced census.

If you take nothing else away from this short statement, please just take the time to look closely, seek outside help or assistance, or at least review your current status in all areas.  You may be surprised at what a difference a few changes can make.

HTS is your partner in therapy. If your facility or company would like a free financial and clinical analysis or consultation, contact us.

GUEST BLOG:

Kerry Wright, OTR/L
Executive Director of Business Development and Southern Operations
Healthcare Therapy Services, Inc.
kerry@htstherapy.com

 

Approximately 350 million people worldwide have arthritis. Arthritis is a condition defined by painful
inflammation and stiffness of the joints. Exercise may be the last thing on a person’s mind when suffering
from arthritis. But exercise is absolutely crucial. A person may think exercise will aggravate their joint
pain and stiffness, but that’s not the case. Lack of exercise can actually make your joints even more
painful and stiff.

Exercise can:

• Strengthen the muscles around your joints
• Help you maintain bone strength
• Give you more energy to get through the day
• Help you control your weight
• Enhance your quality of life
• Improve your balance

Keeping muscles and surrounding tissue strong is crucial to maintaining support for your bones.
Not exercising weakens those supporting muscles, creating more stress on your joints. Exercise is
considered the most effective non-drug treatment for reducing pain and improving movement in patients.


How Therapy Can Help!
Although exercise is extremely important in managing arthritis symptoms, it may be hard to get started
and to maintain an exercise program. Overcoming the hurdles of pain, exhaustion, or boredom can be
very difficult, especially on your own. A physical or occupational therapist can help you to overcome
these hurdles and gain success in maintaining your exercise routine.

Physical therapists evaluate your needs and teach you how to exercise appropriately for joint mobility,
muscle strength and fitness. Physical therapists can also recommend exercises for you to do on your
own. These exercises might include; range-of-motion exercises, aerobic exercise and strength training.
Occupational therapists can also help by teaching you how to protect and reduce stress on your joints
while exercising and performing daily tasks. Talk to your doctor today about the benefits of both
physical and occupational therapy for your arthritis needs!

Sources: Arthritis Foundation

Communication is an important life skill that connects us to those around us. The ability to communicate effectively is important at any age, but for older adults it can be absolutely vital. Older adults need to be able to successfully describe what they need in order to avoid emergency situations. Speech Therapy can be a valuable tool for adults struggling with communication.

As people age, normal changes occur in their speech, language, memory, and swallowing. Vocal cords can become less elastic and larynx muscles can weaken, making it difficult to talk in a manner they are accustomed to. In addition to speech issues associated with normal aging, older adults may experience complications with communication or swallowing due to their heightened risk of dementia, Parkinson’s
disease, or stroke.

Common Signs of Communication Barriers

At Healthcare Therapy Services our Speech-Language Pathologists can assist in differentiating between normal aging and disordered communication or swallowing function. We also provide vital services to those who have communication, cognitive, or swallowing impairments following illness, trauma, or disease.


MAY IS BETTER HEARING & SPEECH MONTH
Each May, Better Hearing & Speech Month (BHSM) provides an opportunity to raise awareness about communication disorders and the role Speech Therapists play in providing life-altering treatment.

Dementia is a result of damage to the brain, resulting in impaired brain function and cognition. The onset of dementia is gradual and can progress over several years. Alzheimer’s disease, which makes up 60% – 80% of dementia cases, primarily affects people over 65 years of age. Common signs of dementia include; decreased short-term memory, decreased problem solving skills, decreased perceptual skills, and personality changes. Read more

These days, damaged joints can be safely removed and replaced with new ones via a surgical procedure known as joint replacement surgery. Joint replacements are a fairly common procedure with more than 1 million patients in the U.S. undergoing joint replacement surgery every year.

The functionality of joints can be affected by a number of factors, including injuries, arthritis, and various other chronic diseases. In more than a few cases, joint damage may be the result of extreme wear and tear. Replacing damaged joints can improve mobility, alleviate pain and discomfort and enable patients to feel and move much better. Read more