Legislation has been introduced to postpone the 15% reimbursement cuts to PTA and OTA treatments. Please help us to support this bill.

Dear Partners and Friends,

Please take a few minutes to read the below message from NASL regarding the new legislation that has been introduced in the US House. We need everyone to support this bill in order to postpone the 15% reduction in reimbursement for Med B services provided by PTAs and OTAs. This cut is set to happen on 1/1/2022. If this legislation is passed, it will delay this cut until 1/1/2023. Additionally, this bill allows for rural and underserved areas to be exempt from these cuts once they are implemented.

As skilled nursing operators and professionals, I urge each of you to take a few minutes to read the letter, make any additional edits/comments, and submit it to your personal representative. Spending a few minutes of your time could result in a very positive impact for our patients, as well as our industry. Your action is extremely time-sensitive because if this bill does not have enough support, it will not move on.

From NASL: Click here to access the letter and the ability to submit directly to your representative.

The time for advocacy on this issue is now as there is not much time left on the legislative calendar for Congress to act before this policy is implemented on January 1, 2022. NASL has prepared a letter for you to email to your respective House members urging them to cosponsor the Stabilizing Medicare Access to Rehabilitation and Therapy (SMART) Act of 2021 (H.R.5536) and asking them to add the bipartisan legislation to any legislative packages moving before the end of the year.

Use the link above or visit https://app.govpredict.com/gr/m5bwzm-u to access and send this email in under two minutes.

Thank you for your time and effort to support this bill!


Cassie Murray, President


Cassie Murray, OTR, MBA, QCP

President of HTS

Healthcare Therapy Services, Inc.

HTS has identified the top 5 therapy clinical outcome focus areas for 2021 based on our experiences from 2020 which allow us to uniquely identify opportunities for clinical growth.


This month’s clinical outcome focus area is:

Part B Programming

One of the many challenges faced during the Public Health Emergency in 2020 included keeping up with the federal, state, and facility specific protocols and strategies to mitigate the risk of exposure to COVID-19. However, with vaccinations and new processes in place based on evolving regulation, utilizing Part B Programming has become less restricted and more able to be optimized. HTS has prioritized 5 ways to maintain quality part B programming in your facility.

1) Take a Deep-dive into Your CASPER
Quality Measures (QMs) are a rich source of information that are recommended to be monitored on a routine basis to assist with quality improvement. QMs directly impact survey results, can influence referral sources and partnerships, and could even be a factor for pay-for-performance which may be where the future is headed. QMs are based on indicators of the outcome of resident care based on resident specific information from MDS assessment information as well as a few claim-based measures.

QM reports are available through the CASPER report system. The CASPER Report MDS 3.0 Resident Level Quality Measure Report identifies all residents, active and discharged, who were included in the QM calculations. The report indicates which, if any, QMs were triggered for each resident. This serves as an important tool that facilitates detailed record review of residents. The information may be used in QAPI activities, survey process, and to potentially identify rehab need.

2) Utilize a Systematic Approach for Therapy Referrals
We have seen the most success when there are streamlined processes for referring to therapy when changes in function are identified prior to the completion of the MDS. Ideally, the quarterly schedule is distributed to the IDT so that there is adequate time for thorough screening, a physician order, and completion of therapy evaluation(s) before the onset of the assessment period.

  • For example, the MDS coordinator would distribute the quarterly assessment schedule at least two weeks in advance of the assessment period.
  • Then, therapy performs the direct screen as well as collaborates with the IDT to identify any areas of change or skilled need.
  • For patients identified as appropriate for therapy services, the physician’s order is obtained and therapy is scheduled to successfully be captured on the MDS as clinically indicated.

3) Look for Change in Function Through MDS Review
The MDS has several sections that are helpful when identifying potential rehab need. Comparing the last two most recent assessments for change in function is an additional screening strategy that can be used in conjunction with the preferred streamlined referral process. The information can also be used as supportive documentation which can then lead to a request for a physician’s order for a therapy eval and treat as indicated.

  • Sections of the MDS that can be used as supportive documentation for rehab orders (if change is observed) include Sections B, C, GG, H, I, and K.
  • SLP focus example: there are a few sections that can help a SLP identify rehab need. Section K codes for swallowing and nutrition and also weight loss of 5% or more in the last month or 10% or more in the last 6 months.
  • Section K0510C is of particular importance for SLPs. In this section, it is made known if the patient has had a change in texture of foods or liquids. If there has been a recent downgrade, this is something to consider when selecting patients for screening purposes.
  • Some MDS software even have reports that can show any diet downgrades that have occurred in a specified timeframe. This orders report that is filtered by diet changes at the resident level serves as another great screening tool.

4) Implement HTS Proprietary Clinical Programming and Pathways
HTS clinical programs are created and introduced in pace with the expanding needs and legislative changes of our industry. Guiding principles for program creation are contingent upon an IDT approach, person-centered care delivery, quantitative research, and quality measure improvement.

Examples of HTS Clinical Programs & Pathways are available below:

The 3 Most Recently Developed HTS Clinical Programs

COVID-19 Recovery

Most recently, HTS has created a Post COVID-19 Rehabilitation Program. This program was developed by HTS clinical staff in response to a large need of individuals who have recovered from COVID-19 and are experiencing lingering health issues. Ideally, outpatients and long-term residents who have recovered from COVID-19 would benefit from this type of therapeutic intervention.

Fall Prevention

STEADY: Comprehensive Therapy Approach to Fall Prevention was designed to provide the best tools and evidenced-based practices to reduce resident falls and improve safe movement.

  • Therapy-driven program utilized by PT, OT, and ST
  • Reviews 12 areas that lead to falls
  • Use of evidence-based assessments and interventions
  • Patient and caregiver education is a vital component
Quality Measures

Star Quality Improvement Program

Therapy expertise and intervention is a key factor in improving quality. Therapy can have a direct impact on quality and outcomes. The HTS Star Quality Improvement Program focuses on utilizing rehab services to assist in improving specific quality measures. Currently, facility ratings are based on the performance of specific quality measures that are listed on the CMS Care Compare website, previously known as Nursing Home Compare.

Modules include:

  • ADL
  • Mobility
  • Pressure Ulcer Prevention
  • Physical/Medication Restraint
  • Pain Treatment
  • Falls
  • Weight Loss
  • Discharge to Community

Therapy driven IDT programming, pathways, and education facilitate quality HTS Part B Programming

HTS therapists are equipped with clinical programs, pathways, and therapy specific education modules to address functional declines in your building. HTS e-Academy has two on-demand webinars available to HTS therapists to facilitate robust Part B Programming. These webinars are entitled “Quality Part B Programming for SNFs” which includes strategies for physical and occupational therapists and “Quality SLP Part B Programming.” Both webinars include a step-by-step guide to process improvement for your part B caseload as well as all the resources needed to accomplish successful program implementation.

5) Review Benchmarking and Trends with Quality Part B Reporting

HTS Therapy Rehab Managers and Regional Directors use Business Intelligence (BI) which is powered through Net Health Therapy (formally known as Optima). BI reports are pulled on a weekly basis to identify areas of opportunity. Action plans are developed and implemented with the IDT as warranted. Key performance indicators specific to Part B patients include but are not limited to:

  • PT/OT/ST B units per visit
  • Percent of long-term residents receiving therapy services
  • GG outcomes
  • Average length of stay by payor
  • Average length of stay by diagnostic category

These 5 solutions to maintain quality part B programming allow HTS therapists to continue to provide function focused, patient-centered care based on medical necessity. The high caliber of clinically driven HTS therapists paired with HTS Part B Programming and report interpretation uniquely positions us to care for your residents.

Need a Powerful Therapy Partner? Contact Amanda Green, Executive Director of Strategic Development amanda@htstherapy.com for information about our contract therapy partnerships.

Looking back from 2020, the start of this New Year has been more reflective than most. As an organization, fully “seeing 20/20” in 2021 has been made possible by the clarity gained through the experiences and challenges we all faced last year. In 2020, we relied more on our clinical knowledge than ever before to develop creative solutions for staffing, in-room treatments and utilizing tele technology–all while emphasizing the patient-centered delivery model. Although it is likely that 2021 will bring similar challenges as those from last year, as an industry we know what we are capable of accomplishing. We are also now better equipped to overcome COVID-19 related obstacles with the use of exponentially expanded partner and therapist toolkits, policies, and procedures.

We at HTS have identified the top 5 therapy clinical outcome focus areas for 2021 to improve processes and clinical delivery across the IDT.


This month’s clinical focus area is:

Workflow Process Improvement

Optimizing processes for workflow improvement allows organizations to work smarter and more efficiently. This can be as simple as reducing redundant information sharing to using static agendas and communication tools.

HTS supports our valued partners with a “best practice” workflow system analysis. Our HTS management team is uniquely positioned to facilitate workflow processes to allow more efficient identification for educational and training opportunities. These action items are then used to drive process improvement with the facility’s interdisciplinary team.

Check out the top 3 ways your building can enhance processes for maximum efficiency and coding accuracy. Use of these HTS tools and resources are available exclusively for HTS partners.

1.  Use of the HTS Preadmission Screening Tool

The HTS PDPM Pre-Admission Evaluation Tool is a 3-page screening document that assists care coordinators in capturing clinically indicated patient characteristics to attain a projected PDPM clinical category and per diem rate (available via a rate estimator). This is a great guiding tool for admissions and clinical liaisons to use while gathering information from the hospital record. This tool also assures accuracy with coding. Our interdisciplinary teams have found this tool to be especially useful when capturing NTA comorbidities and CMG classification.

2.  Formalized Meeting Guides

PDPM implementation required system adaptation and modification for success. The PDPM Initial Medicare Assessment Meeting Tool is highly recommended to bring the team together for a guided, patient-specific clinical discussion. Suggested medical record items for interdisciplinary meeting discussion are recommended and a template for documentation of communicated action items is also provided.

Buildings that have implemented use of this specific tool have observed a marked improvement in the quality of communication. Additionally, they specifically saw an increase in timeliness when querying the physician and an improved ability to capture NTA comorbidities. Providing a standardized and formalized platform to determine usual performance for Section GG has also streamlined consistency across the record. Our partners agree this is definitely a “must have” for PDPM meetings.

We also recommend use of a weekly Medicare Meeting Form to provide a more structured, formal discussion of patient specific clinical complexities. The HTS Medicare Meeting Form which was revised in 2020 paired with use of the Medicare Meeting Discussion Guide ensures all attendees are present, timely, and prepared to stimulate discussion with the team.

3.  Optimization of IDT Communication to Achieve Consistency Across the Medical Record

“Consistency across the record” is one big component all providers strive to achieve. This consistency is primarily accomplished by effective interdisciplinary communication. MDS coding lacking supportive documentation puts a claim at risk for medical review, which could negatively impact reimbursement.

Rate setting, captured by coding on the MDS, involves a team approach to integrate systems in order to achieve reimbursement appropriate for the patient’s clinical complexities. For example, Section GG requires multiple disciplines between days 1-3 to determine the usual functional performance. Simply attaining function scores from one discipline, such as only nursing or only therapy, puts the claim at risk for medical review. Furthermore, coding that is not supported by documentation within the chart is another risk factor for medical review.

Since Section GG contributes to 3 of the 5 components of the PDPM rate, effective GG function score procedures are imperative for success under PDPM. Some great solutions are available within the Section GG Workflow Resources section of our PartnerHQ portal. Tools such as the Function Score Quick Tips are also available to optimize processes in your building to minimize medical review risk and achieve consistency across the medical record.

Need a Powerful Therapy Partner? Contact Amanda Green, Executive Director of Strategic Development amanda@htstherapy.com for information about our contract therapy partnerships.

HTS has identified the top 5 therapy clinical outcome focus areas for 2021 based on our experiences from 2020 which makes us better equipped to overcome COVID-19 related obstacles. Furthermore, after attending a 15-hour training and certification process, HTS management staff have all become “PDPM Masters.” These additional “feathers in our cap” allow us to uniquely champion process improvement initiatives alongside your interdisciplinary team. As HTS continues to identify opportunities for clinical growth, a key process improvement area will be discussed each month.


This month’s clinical outcome focus area is:

Medicaid CMI

HTS has made it our goal to partner with our clients in every facet of the skilled nursing facility – not just within the walls of the therapy gym. Through business review meetings and discussions with HTS therapists and regional directors, we have become aware of the need for a more detailed look at Medicaid CMI. The HTS team immediately went to work to create a deep-dive analysis program. Now, HTS management is able to apply operational, clinical, and strategic insight to provide solutions to help our clients efficiently assign a dollar value to the treatment of Medicaid patients that is consistent with medical needs. HTS is here to serve you as a facilitator of opportunity and process improvement initiatives through a Medicaid CMI Deep-Dive. Medicaid CMI success is achieved through a three-pronged approach:

Medicaid CMI Deep-Dive Services currently available to HTS Clients

HTS management completes report interpretation at the site level by analyzing data provided within the Time-Weighted CMI Resident Roster Report. A summary of potential vulnerabilities and opportunity areas are identified and reported to the interdisciplinary team. Opportunities are then discussed and assigned to a process improvement champion. Timeframes are designated to keep the team on track with system development. CMI information is then tracked on a quarterly basis to show benchmarking and trends. This value-add service comes with a standard rate of $500. However, for HTS clients, this proprietary deep-dive is offered as a complimentary service.

See below for additional step-by-step details of the deep-dive process:

  1. The Time-Weighted CMI Resident Roster Report for the last 4 quarters are requested.
  2. Reports are interpreted and analyzed by the HTS Management Team
  3. A site-specific, customized presentation of Medicaid CMI data analysis is provided. Opportunities for Medicaid CMI improvement are identified and discussed.
  4. Medicaid CMI data tracking continues as reports are received.
  5. HTS Regional Directors are your “boots on the ground” to facilitate process improvement initiatives.

Need a Powerful Therapy Partner? Contact Amanda Green, Executive Director of Strategic Development amanda@htstherapy.com for information about our contract therapy partnerships.

HTS has identified the top 5 therapy clinical outcome focus areas for 2021 based on our experiences from 2020 which makes us better equipped to overcome COVID-19 related obstacles. Furthermore, after attending a 15-hour training and certification process, HTS management staff have all become “PDPM Masters.” These additional “feathers in our cap” allow us to uniquely champion process improvement initiatives alongside your interdisciplinary team. As HTS continues to identify opportunities for clinical growth, a key process improvement area will be discussed each month.


This month’s clinical outcome focus area is:

PDPM Case Mix

“It’s not enough to be providing excellent patient care anymore. Under PDPM, if you don’t code correctly on the MDS, you’re not going to get credit for it.” – Sheena Mattingly M.S., CCC-SLP, RAC-CT, HTS Director of Clinical Outcomes.

HTS has identified 5 areas of opportunity to improve PDPM Case Mix. Let’s take a deeper-dive by discussing the 5 areas of attack to optimize PDPM case mix classification coding.

1.  Assure good communication and collaboration of the function score (Section GG) which drives the nursing, and PT/OT CMG classification.

At this point we are all aware of Section GG’s impact on Medicare reimbursement under PDPM, but odds are we still need some fine tuning. Review current processes for attaining Section GG coding to assure IDT collaboration of usual performance is documented and available within the medical record. Section GG is of utmost importance not only for PDPM reimbursement but also for Quality Measures, SNF QRP, and 5-Star Rating.

2.  Review your facility’s process for querying the physician to capture any coding opportunities. HTS recommends use of our Initial Medicare Meeting Tool.

Imagine this all too familiar scenario, the speech-language pathologist (SLP) in your building identifies a newly admitted patient has aphasia. This SLP then brings this information to the Initial Medicare Meeting and presents her findings. The IDT agrees and proceeds to query the physician for a diagnosis so that the aphasia is considered active within the 7-day lookback period and can be coded in section I4300 of the MDS. This example of excellent communication results in a more accurately coded MDS that is reflective of the patient’s clinical needs. More specifically, the coding opportunity identified is counted as a SLP-Related Condition in the SLP PDPM “bucket” which is directly tied to PDPM reimbursement.

3.  Use the HTS IMA SLP Component Communication Tool.

This tool is to be assigned to be completed by a SLP or an OT. It is designed to be used to identify potential coding opportunities from the SLP’s or OT’s skilled perspective. The opportunity can then be presented to the IDT for discussion. Prior to PDPM, components such as Section K of the MDS or coding of a mechanically altered diet did not correlate to a rate setting. Now, we do get “credit” for these types of clinically indicated coding opportunities which means communication is key.

4.  Use the HTS Nursing Case-Mix Classification Quick Tip Handouts which is available to HTS Partners on the PartnerHQ Web Portal.

Each nursing component Quick Tip Handout is paired with a HTS High Impact Webinar available on demand on the PartnerHQ Web Portal. For example, when reviewing the Special Care High Quick Tip Handout, you will see that a commonly overlooked classification item may be a patient with COPD. If this patient has shortness of breath while lying flat and this is documented within the medical record, this patient would classify as Special Care High versus Physical Functioning. There are several Quick Tip Handouts. They are a one-page resource that aide in familiarizing yourself with the details of the components for each nursing classification.

5.  Rely on the HTS therapy department for key performance indicator data analysis.

HTS Therapy Rehab Managers use a PDPM Analytic Business Intelligence Dashboard which is powered through Net Health Therapy (formally known as Optima). This report is pulled on a weekly basis to identify areas of opportunity. An action plan is then discussed with the therapy team and the HTS Regional Director is also consulted to drive process improvement. Key performance indicators analyzed include but are not limited to:

  • PDPM Covered Day Count and Patient Count
  • Case Mix Group Distribution
  • Treatment Minutes per Visit
  • PT/OT/ST B Units per Visit
  • Section GG Outcome Data

Need a Powerful Therapy Partner? Contact Amanda Green, Executive Director of Strategic Development amanda@htstherapy.com for information about our contract therapy partnerships.

In recognition of this week, we would like to take this opportunity to commend our partners and healthcare heroes for your unwavering commitment to improving the lives of those you serve.

To celebrate this week, HTS has created a fun activity for residents and staff.

HTS will present cash prizes of $200, $100 and $75 to the top three communities that show the best participation! Be sure to take photos and let us know how your community shined this week.

Sunshine Award

Get your residents and staff involved in this fun coloring activity to share sunshine and appreciation. Tell someone they brighten your day by presenting them a Sunshine Award.

Display your Sunshine Awards on resident doors, decorate the halls, promote/share on Facebook, and find other creative ways to get your community involved!

Choose from multiple awards to download, print, and distribute for residents and staff to color and share their appreciation. Click here to download yours today!

Blog by: Stacy Baker, OTR/L, RAC-CT, CHC, Proactive Medical Review

Following a year of little to no medical review and extensive government spending, most experts forecast reimbursement compliance audits ramping up in 2021. Multiple areas are ripe for potential scrutiny, including, but not limited to PDPM coding and supportive documentation, the proper use of SNF waivers, and appropriate access to and accounting for Provider Relief Funds. Get the facts and ensure readiness with these insights into the current audit environment and the medical review entities that may rain on providers in the months ahead. CMS suspended audits between March 30 and August 3 of 2020 in order to reduce provider strain during the COVID-19 pandemic. This year, however, audits are resuming in full swing.

  • Under the new Biden administration, many industry leaders and healthcare attorneys predict an uptick in audits and healthcare prosecutions with “both government initiated litigation and qui tam suits…set for continued growth in 2021” according to Georgia Ravitz et. al (i) With Xavier Becerra, a former prosecutor, appointed secretary of HHS, the government is poised to advance fraud prevention efforts.
  • False Claims Act (FCA) recoveries in FY2020 were $2.2 billion, down from $3.1 billion in 2019 and lower than any year since 2008 at a time when spending has escalated throughout the pandemic. Healthcare made up 85% of FCA recoveries in 2020 and that trend is likely to continue through both standard channels and a focus on new risk areas such as telehealth billing fraud. ii
  • Recovery Audit Contractors are now authorized to review for Medical Necessity and Documentation Requirements specific to the Patient Driven Payment Model (PDPM), and the OIG has added new focus to the Work Plan to identify program integrity risks associated with Medicare telehealth services during the pandemic.

Click here to continue reading this blog.


About Proactive Medical Review
HTS partners with Proactive Medical Review, a third party company who specializes in ensuring compliance with regulatory standards and promoting measurable care excellence. The team includes SNF experienced nurse, MDS, Health Facility Administrator, therapist and reimbursement specialists with experience serving in multi-site contract therapy operations, as corporate directors of quality, clinical program specialists, and Compliance Officers. Proactive is uniquely positioned to assist in managing the many changes and challenges facing providers partnered with HTS. Learn more about our commitment to compliance here.

HTS has identified the top 5 therapy clinical outcome focus areas for 2021 based on our experiences from 2020 which makes us better equipped to overcome COVID-19 related obstacles. Furthermore, after attending a 15-hour training and certification process, HTS management staff have all become “PDPM Masters.”

These additional “feathers in our cap” allow us to uniquely champion process improvement initiatives alongside your interdisciplinary team. As HTS continues to identify opportunities for clinical growth, we look forward to discussing these key process improvement areas in the coming months.

Top 5 Therapy Clinical Outcome Focus Areas:

  • Working Smarter with Workflow Processes
  • PDPM Case Mix
  • Medicaid CMI
  • Section GG Outcomes
  • Part B Programming

*In February, we announced all HTS Regional Directors and Assistant Regional Directors earned their PDPM Master Class Certification. This 12-month course for skilled nursing facilities was offered through Leading Age Indiana in 2020. The certification process included 15 hours of training and competency assessment provided by nursing and MDS experts at Proactive Medical Review.

HTS supports our valued partners with access to high demand IDT toolkits, trainings, and many other process improvement resources conveniently available on HTS PartnerHQ web portal. Not a partner? Contact us to discuss how your community can be part of these focus outcome discussions.

Presenting:  Staying Healthy During COVID

During this presentation, we discuss the impact COVID has had on our daily lives and overall wellness. A closer look at our emotional, social and physical wellness is discussed with strategies and tips to stay in good physical and mental shape.

Toolkit Includes:

  • VIDEO – Staying Healthy During COVID Presentation Recording
  • MARKETING FLYER – Use this flyer to advertise the presentation video airing on your community TV channel or a specialviewing in the lounge area.
  • HANDOUT – Tips to Stay in Good Physical & Mental Shape

HTS Partners can conveniently access this toolkit along with many other wellness resources under the Wellness Dashboard on HTS PartnerHQ web portal.

Exclusive PDPM Training For HTS Partners

We are committed to supporting our partners by offering exclusive PDPM webinar and live trainings in critical areas to foster success as we “Power through PDPM.”

Moving From RUG-IV to PDPM:  The Transitional IPA

Wednesday, September 25, 10:00 a.m. – 11:00 a.m.

Join us for the 1st High Impact PDPM Workshop where we will review how to successfully navigate the upcoming transition from RUG-IV to PDPM. This webinar will focus on completion of the required transitional Interim Payment Assessment (IPA) for current Medicare Part A beneficiaries including gathering quality assessment data and considerations for ARD scheduling.

Presented by: Eleisha Wilkes, RN, RAC-CT


PDPM Billing Processes

Wednesday, October 23, 10:00 a.m. – 11:00 a.m.

The importance of billing accuracy becomes more important than ever under the PDPM (Patient-Driven Payment Model) effective October 1, 2019. This session will focus on tools and strategies to establish a robust Triple Check process that providers cannot afford to overlook.

Presented by: Stacy Baker, OTR/L, CHC, RAC-CT


Please contact us to register. Not a partner? Contact us to learn how we’re providing even more value to our partners.