Mediware Rehabilitation Blog

Meaningful Use of Data

Electronic Health Records (EHR) are electronic file cabinets for collecting and storing primary information about patients seen in care. The effort to adhere to the requirements of entering that into an electronic documentation system demands some change in clinical behavior. Often, “it takes too long” is expressed when the discipline of electronic entry is compared to handwritten charting. However, these personal time costs have the potential to reap significant benefits when those data are called upon to answer questions beyond simple evidence of what was performed.

The ability to look back at performance and patient data in aggregate and provide evidence of effectiveness and efficiency is the basis for clinical analytics (CA). CA is rapidly becoming the clinician’s practice resource for achieving best practice as population based healthcare management transforms how we work and how we will get paid.

Our choice of tools must not be determined by behavioral changes required to use them, but rather their payback in knowledge gained through their use. The value of an EHR or outcome measure is not determined by the learning curve associated with getting up to speed and competency but where they point us to in knowledge gained for future practice decisions. Meaningful use of these tools is demonstrated by the output of their associated CA. Whether performed on the desktop or research center, CA and electronic clinical records use will unlock the clinical pathways to what works best for who in planning care. Recent evidence of this evolving technology was published[i] by Dr. Alan Jette and colleagues; using the AM-PAC Functional Assessment to predict discharge destination from acute hospitals. Adding to the knowledge of where continuing care resources are most appropriately applied is one of Medicare’s most pressing issues; EHRs and CA provide evidence and value for future clinical practice in post-acute rehabilitation.

[i] Jette, D, et al,; AM-PAC “6 Clicks” Functional Assessment Scores Predict Acute Care Hospital Discharge Destination. Physical Therapy, September 2014 vol. 94 no. 9 1252-1261

Site Neutral Payment Proposal Has Flawed Understanding of Rehabilitation

CMS has built levels of care with specific expectations and resource allocation unique to the various care provided by them. Although it has created disparate silos of care, inability to sometimes compare continuum services and general legal expectations for documentation, oversight and reimbursement formulas, suddenly there is an expectation that 'site neutral' payment is and can be substituted for certain conditions when treated by SNF's and IRF/U's.  Do you agree?

Proposed Rehabilitation Standards Need Your Professional Feedback

Inpatient Rehabilitation as a specialty is being challenged more each day for the care and skills uniquely provided in the IRF/U environment. Continuing to defend the highly individualized and specific skill sets of patients that enter IRF somehow are not apparent because 'Rehabilitation' as a word has been highly generic in terms of explaining recovery for just about any impairment. CARF certification standards certainly demonstrate that the basic expectations for a rehabilitation level of care are highly unique, individualized and specialized for the patient population treated; each year CARF provides opportunities for comment on new standards. An invitation just arrived. Please be a part of this review! 

Auditing IRF Records is Essential - Are You at 90% Risk?

90 percent seems like a good number unless it's 90 percent incorrect. Recently, CMS hired Strategic Health Solutions as their Supplemental Medical Review Contractor (SMRC) to look at IRF/U documentation and see if it was meeting the required medical necessity documentation and regulatory requirements. Unfortunately, the findings were not in favor of payment. Let's look at what they discovered. If you haven't heard it loud and clear you MUST audit your own records for the appropriate elements of charting or you too could be in the risk pool for non-payment.

If you were a part of this initial review, AMRPA would like to speak to you!

IRF Quality Indicator Submission Deadline: Friday Aug 15th

Each year the IRF final rule publishes the 2 percent reduction amount in the standard payment rate that will take affect for the present fiscal year as it relates to submission of quality indicator information received or not received in the fiscal year from two cycles prior. Reductions in the standard payment would be applied in the 2015 fiscal year for those not participating in ALL indicators from 2013. 2014 submissions will affect 2016 payment year, 2015 will affect 2017 payment year, etc. 

CMS just released an announcement for the deadline of 2014 first quarter data. Here are the facts, links and helpful numbers so that YOU can stay ahead of the transmission deadlines and not be affected in the 2016 payment cycle.

IRF 2015 Final Rule Decisions - [CMS-1608-F]

The IRF Proposed Rule this spring held many changes, so many in fact facilities were wondering if they had the time to educate and be ready for the 2015 payment year. In the Final Rule there were several surprises. Did Medicare realize the overwhelming number of changes may be a bit too much? Perhaps, but whatever the final reason, some changes are on hold until next year's cycle.

Here is a summary of those items that will stay and those that will wait just a bit longer!

3 Hour Rule - Defining an IRF/U level of Intense Therapy Services

3 Hour Rule continues to be a main defining factor that CMS has set as the 'threshold' to determine if the patient in an IRF/U receives an intensity of therapy services specific to an acute rehabilitation level of necessity. In this blog, respondents to a 3 Hour Rule survey share information and details on the 3 Hour Rule as operationalized in their facilities.

Rehab Goals, Outcomes and Cost

Establishing and working to achieve functional goals to address patient problems is the cornerstone of clinical practice for all therapists. Regardless of professional discipline or therapeutic focus, the requirement to execute a problem-oriented plan of care and monitor its effectiveness is basic to all rehabilitation practice.

Functional Limitation Reporting - Claims Based Outcomes Reporting

Mediware was privileged to have Heather Smith, Director of Quality, APTA, provide an extremely informative webinar on Tuesday, April 15. The presentation still proves that there is a lot of confusion around G-codes. A number of follow-up questions were included in the webinar survey and we've highlighted some of the most asked questions.

What Does Functional Limitation Reporting Tells Us?

Mediware has provided a set of online tools to assist therapists with the translation of functional measurement scores to severity modifier codes as prescribed by CMS (Claims-Based Outcomes Reporting G-code Modifier Calculator). A recent analysis of this activity reveals preliminary evidence of the functional measure use patterns deployed by therapists in clinical practice.

SGR, Therapy Caps, ICD-10 Delay – Signed on April Fools' Day – Go Figure!

If ever a bill held substance that directly impacts rehabilitation management of issues we now face, this could be the one. Don’t pass up your chance to read it and understand its contents better. H.R. 4302 pushed quickly to address an impasse on Senate Bill 2110; this bill includes several extended mandates and even a twist – another delay to ICD-10! And the kicker – final signature and passage occurred on April Fools' Day. Is this an impending statement? You decide!

Why is it important you review this bill? What affects you, the rehabilitation provider? Let me carve out just a few of the sections that impact you TODAY, perhaps in the same way as yesterday or slightly different!

Pedal to the Metal for ICD-10 -- Maybe not?

Just when you think ICD-10 is full force “pedal to the metal”, as regulatory
indications have all prepared us to accept Oct. 1, 2014 – AMAZINGLY Congress pulls another possible lame duck intervention in a fast tracked bill that includes SGR fix and Therapy Caps extensions AND a possible delay to ICD-10 coding! To everyone’s surprise, even the moderator of our March 26th webinar as she was speaking the present known facts for ICD-10 implementation, Congress was conjuring up a delay extension language for to Oct. 1, 2015. CAN IT HAPPEN? The next few days and congressional actions alone will tell!

CAPS Don't CAP Costs - They Also Hide Costs

CAPS = "Limits on Therapy Services" that have increased the cost of care to providers while intentionally trying to control costs for part B Medicare services. In my opinion CAPS have backfired. Control costs? Do we know how many administrative dollars are being poured into the process at both the provider and Medicare contractor levels? No one seems to be talking about those costs! Uncovering the 'real cost' of this legislation diverts money to the wrong end of beneficiary access and hurts those most needy to receive the benefits provided by therapy services. Let's discuss these realities as we educate our lawmakers and ourselves on the history of CAPS.

CARE Tool Revisited

This week the House Ways and Means Committee drafted the Improving Medicare Post-Acute Care Transformation Act of 2014, proposing the first data standards for post-acute care. While only draft legislation, it builds upon all previous work done by CMS to define a common assessment instrument and its data elements.