The Seismic Shift

This is a new white paper from KeySys Health.




You Won’t Believe This One! (Yes this is a true story) In an outpatient-therapy center that will remain nameless, I was working with a physical therapy manager who was waxing eloquently about how clean he kept his center (this was my first clue that in the words of Miss Clavell – from Madeline fame – “something was just not right”). We were standing in his main gym area where I observed a generally acceptable center. Until…I happened to look over his shoulder and noticed a bright pink fly swatter hanging on the hydrocollator pad drying rack. Intrigued by what new clinical outcomes fly swatters where producing in the latest professional and peer-reviewed journals, I just had to ask why they had a fly swatter hanging in such a conspicuous and unconventional place. Neither the manager, the PT, the tech, nor the scheduling secretary had any idea as to why the lovely wire handled – pink plastic weapon of fly death was hanging on the rack (with pads brushing against it). Now you may ask of this potential safety issue, “how could something like this happen?”

My last blog, “Rehab Agency Certification: Comply or Not Comply 4/28/10,” provided an overall review of the Medicare compliance program for OPT/Rehab Agencies. So what if you are not Medicare certified, why should you have a safety program in your outpatient-therapy center?

In my professional career I have worked with hundreds of outpatient-therapy centers preparing for, and responding to, various levels of on-site audits, surveys and reviews. I’ve heard the arguments time and time again that outpatient-therapy centers are so low risk in terms of hazardous work places, why should they take time to do the “stuff that hospitals have to do?”

Why bother with policies, procedures, safety checks or chart reviews? Well for one it’s the right thing to do. Second, many managed care payors are requiring on-site reviews as part of their own credentialing process to keep providers in their networks. Moreover, as an employer you have a duty to comply with the OSHA. OSHA has even noted the outpatient-therapy work environment on its website and provides excellent reminders of what you may face in your center.

Understandably, independent physical, occupational and speech therapy practitioners wear many hats in their practices therefore the last thing you think about is performing many of the mundane tasks. Your day is typically focused on scheduling, caring for your patients and driving revenue through your center.

Those “last” things need to be some of the first things you do. If not, the time will come when you will regret not taking a few minutes to do that safety check. Whether or not your clinical practice is Medicare certified, it really doesn’t matter. I have seen many therapy practices (large and small) that haven’t performed a fire drill in years!

You as a practice owner or center manager, you have the responsibility to provide for the safety of your patients, but also you and your employees. The APTA provides a great outline of what you need to have in place from an administrative standpoint to ensure safe clinical operations.

Here are some other practical tips you can use:

1. Start by taking a safety inventory of your center. Ask a friend to be “new eyes” and look for things you may miss in your normal day (like the pink fly swatter). You don’t need a prescribed form yet, just do a “walk thru” and look for the obvious. Start in the parking lot and work your way through the center to the back door. It’s amazing what you will see – blocked exits, improper lifting techniques by your other therapists (yes, they get in a hurry and forget too!), and clean towels touching the floor just to name a few. Make sure to keep a list of everything you find.

2. Now categorize your findings and address the obvious: You don’t need a committee to move boxes from the hallway and from in front of the emergency exits. Take care of the things you can control and do it today. Don’t wait.

3. Some things may have to be corrected by trained professionals. Lighted exit signs that don’t work, installing panic bars on your emergency egress, and other big jobs that need to be scheduled and budgeted. Don’t put these off. Develop a plan and execute it.

4. Meet with your staff regardless of size. Inform them to always ask “why” something is where it is or isn’t. Never take an expiration date, frayed wire or laundry procedure for granted. If it can be done better, well it probably can.

5. Last, schedule monthly safety inspections. Feel free to use my complimentary healthcare facility inspection checklist. It is a basic overview of what you’ll need to look for each and every month. Don’t be afraid to mark something as being out of compliance, but just remember to address it and act on it! Keep it in a binder or file for documentation purposes.

Good luck as you continue to work to be the best center you can be. And stay on the lookout for those pink fly swatters!

Jeff has participated in more than 2,000 Medicare surveys and has more than 20 years experience consulting with organizations to develop sound policies and procedures to comply with internal and external standards. His unique experience has allowed him to see the clinical, administrative and payer aspects of healthcare. Jeff is also a certified deemed status surveyor with the AAAASF/RA” Division.

For more information on this or other ways to improve your clinical processes please contact Jeff Dance, Senior Consultant at KeySys Health, LLC. Phone: 205-612-1750 or email jdance@keysyshealth.com .

Well it’s now the start of Q2. Taxes are filed (hopefully), Spring Break is now behind you, 2010 business plans are in full swing, and I’ll bet you have forgotten to conduct most of your Medicare compliance activities as an OPT/Rehab Agency. With last year’s removal of social work from 42 CFR 485.717 “Rehabilitation Program” compliance is now much easier than ever before.

It’s always the worst day – you are up to your neck in patients, you have a front desk person out today, and there she is with notebook in hand…Mrs. Medicare Surveyor standing in your front waiting area! Are you ready?
As you probably don’t sleep with the Medicare Conditions of Participation, 42 CFR 485.703 et seq. under your pillow, let me give you some quick reminders…

1. Governing Body: Make sure you have minutes in place for a review of your overall program. If you missed a meeting go ahead and confess it. Just provide the reason why and put in corrective measures to prevent it in the future. Try to conduct your meetings quarterly if at all possible. Remember, all committee reports should be sent up to your GB for review. And the good news…you don’t have to meet in person. You can always conduct a “telephonic GB meeting.”

2. Safety, Infection Control, and Program Eval: Again, these are best conducted on a quarterly basis and should be held prior to the GB meeting. Make sure you have good documentation of fire drills, monthly safety inspections, pest control and laundry contracts, along with your Program Eval activities (for more info see my blog “Rehab Agency Program Eval: Are You Ready” February 11, 2010. https://keysyshealth.wordpress.com/category/medicare-compliance/ )

3. Policies & Procedures: If you haven’t reviewed your P&P Manual, now is the time to do it. Make sure you are doing what you say you are going to do. Mrs. Medicare Surveyor will grade you on 2 aspects: (1) Do you have the polices the regulations require? (2) Are you following these policies as written in your manual? Noncompliance with either of these can substantiate a deficiency.

4. Medical Records: Whether you use paper or electronic records you should be able to quickly produce quality records for Mrs. Medicare Surveyor. These must have the basics- script, medical history, initial eval, plan of care, SOAP notes, 30 day plan of care (if needed) and a discharge summary (if applicable). The easy points come with just having these components in your chart.

5. Physical Plant: Don’t forget your first impression. It’s Spring so go ahead and do the cleaning. Get rid of those expired meds (yes check that drawer for old Neosporin ®, Leukotape ®, and the other odds-n-ends you collect over the year). Again, these are the easy points and can keep Mrs. Medicare Surveyor from digging further. Oh yea, don’t forget to take a look at the bottom of those BioFreeze ® bottles. They expire too.

Good luck as you maintain your compliance. Remember, that your successful survey depends on basic attention to detail. Don’t assume Mrs. Medicare Surveyor is busy somewhere else…your office maybe right on her way home when she decides to “stop in for a look-see.”

Jeff has participated in more than 2,000 Medicare surveys and has more than 20 years experience consulting with organizations to develop sound policies and procedures to comply with internal and external standards. His unique experience has allowed him to see the clinical, administrative and payer aspects of healthcare. Jeff is also a certified deemed status surveyor with the AAAASF/RA Division.

For more information on this or other ways to improve your clinical processes please contact Jeff Dance, Senior Consultant at KeySys Health, LLC. Phone: 205-612-1750 or email jdance@keysyshealth.com .

Did Toyota Go Too Lean?

Unless you have been under a rock for the past decade you know that Toyota has been the standard-bearer for all that is right in quality and efficiency. Their Lean Production methods have been morphed into all industries, including healthcare. Everyone has jumped on the Lean Bandwagon – was it the right move?
Now with news of accelerator design problems and leaky hoses, Toyota finds themselves with a great deal of explaining to do. How could the model of production excellence go down the path of the lemon?

These questions are not easily answered. Just as Toyota took more than 30 years to perfect its methods, so to will it take more than a trip to Washington, DC to correct the problem. Supply chains, inspection processes, and more have to be evaluated to ensure the Toyota products are back to their impeccable service records. It takes time.

So what can you do as a healthcare provider following Lean Methods prevent a Toyota situation in your practice or organization?

1. Don’t Stop. No one said Lean is “Mean.” (Sorry for the rhyme. It just worked.) This is a perfect time for you to reevaluate your Lean Methods and double-check everything. You will eventually win out in initiatives such as Meaningful Use, PQRI and the RACS by sticking with sound Lean principles.

2. Remember this is a journey. Any Lean professional will tell you, the Lean process is a journey. These recent events will provide even better clarity for you as hone your Lean methods.

3. Reengage your colleagues. Now is the wake up call for your colleagues to recognize that everyone has a part to play in making sure from design, to execution, your processes, services and products must be the best. Lean methods are not just about efficiency; they are also about quality.

4. Remind everyone – your goal is to exceed all expectations. Rework and cutting corners is the rope that given enough of it will hang you in the end. Don’t let that happen to you.

5. Keep learning from your mistakes as well as others. No need to throw Lean out with the bath water. However, keep pushing to find those areas where you can improve. It’s not about the program it’s about “doing the right things right.” Lean is just a mechanism to achieve your goals.

Did Toyota go too lean? Maybe they did in some areas. One thing is for sure they will certainly rise above this current issue. We can all learn from this to make healthcare more efficient, safer and the best it’s ever been.

For more information on this or other ways to improve your clinical processes please contact Jeff Dance, Senior Consultant at KeySys Health, LLC. Phone: 205-612-1750 or email jdance@keysyshealth.com . Visit our website at www.keysyshealth.com

Jeff has more than 20 years experience in healthcare consulting organizations that develop sound policies and procedures to comply with internal and external standards. His unique experience has allowed him to see the clinical, administrative and payer aspects of healthcare.

Creditor Rules Apply to Healthcare Providers

Last August (2009) the Federal Trade Commission implemented a new law regarding the way businesses prepare for the protection of consumers’ credit information and privacy. These are the “Red Flag Rules.” As many people have unfortunately experienced, identity theft is a real problem in today’s society – to the tune of $54 billion. One study showed this figure is up 37% in less than two years!

Regardless of your medical discipline and type of practice, your patients rely on you to protect their identity. Healthcare providers are settling into maintaining compliance with HIPAA rules for patient privacy. Now they are faced with financial privacy practices.

So what do you need to know to comply with Red Flag Rules?

1. Understand your role as the creditor. If you bill patients for any coinsurance and/or copays you become a “creditor.” This includes any payment plans for any uncollected amounts. Whether you finance it or work with another funding source, you are responsible for the patient’s identity protection.

2. You are NOT a creditor if you require payment at the time of service, or before, services are rendered. Once the patient leaves the premises with an unpaid balance, you become the creditor.

3. You are NOT a creditor if you take all acceptable forms of payment at, or before, services are rendered. This includes credit and debit cards.

4. Once you set up a payment plan, regardless of terms and conditions, you have essentially held yourself out as a creditor. This is called a “covered account.” Therefore, you are responsible for implementing at “TPP” or Theft Prevention Program under the Red Flag Rules.

What can you do now?

1. Develop Policies and Procedures specific to your practice to identify Red Flags that may point you to identity theft.

2. Develop ways to protect patient identity. This includes monitoring your own colleagues as well as patients.

3. Train and educate staff on how to spot someone trying to be admitted under a stolen identity. Forged driver’s licenses, insurance cards, etc may be immediate Red Flags.

4. Always double check the patient’s information in your systems to a current photo ID. Especially addresses where bills are sent.

5. Notify law enforcement if you notice trends where patients call about suspicious bills from your office.

6. Review and revise your policies, training and your internal auditing processes on a regular basis. This is important whether you are a one-clinician practice or a large healthcare system.

Remember, it is your responsibility to identify any and all Red Flags that may jeopardize a patient’s identity.

Visit the Federal Trade Commission’s website at www.ftc.gov for many other resources, or contact a healthcare practice consultant regarding Red Flag Rules. We even provide a low-risk worksheet to get you started.

For more information on this or other ways to improve your clinical processes please contact Jeff Dance, Senior Consultant at KeySys Health, LLC or call: 205-612-1750.

Jeff has more than 20 years experience consulting with organizations to develop sound policies and procedures to comply with internal and external standards. His unique experience has allowed him to see the clinical, administrative and payer aspects of healthcare.

Improve Cash Flow for Your Practice in Today’s Healthcare Environment

In today’s economic turmoil cash is not only king, but is taking on god-like status. Revenue Cycle Management (RCM) is the current financial discipline needed in all medical practices for sustained success. From hospitals, to physician practices, to the virtual world of medical supply and service ordering, RCM is truly a discipline.

New ways of ensuring patient eligibility and payment responsibility are necessary. Never shy away from developing and instituting policies on your Over The Counter Collections (OTC) Here are some practical tips to help your practice collect cash “over the counter.”

1. Define the process. You don’t need a PMP or Six Sigma expert. Just plain common sense and discipline is needed to understand and apply the steps from referral to getting the patient’s account to a zero balance.

2. Educate and train your staff on the process and the expected goals. Everyone is responsible for ensuring sound financial performance in your medical practice.

3. Keep a scorecard. Nothing works better than posting results. Define the metrics and measure your success. OTC goals should be identified daily, weekly and monthly. Also make sure to celebrate your successes.

4. Audit the process on a regular basis. This includes not only the process but also the compliance with the process. Never forget to make sure you listen to the front line. They should always have input on how to make it better.

5. Automate! There are many billing software solutions healthcare consulting firms that are discipline specific to enable you to use real time eligibility. You’ll know what is expected of the patient and there is immediate accountability.

6. Ask for payment up front. Co-pays, coinsurance, and deductible amounts are all part of the OTC. Take credit and debit cards but make sure you have controls in place to protect this information.

Lastly, remember this point… You are not a bank! Therefore, don’t institute policies that make you one. Instead use these pointers, in addition to your overall intake, billing and collections processes to improve your cash collections. Many practices don’t see the front counter as a place to transact business. What happens at, and over the counter is critical in maintaining your financial success.

Jeff Dance is a Senior Healthcare Consultant at KeySys Health, LLC. He has over 20 years experience in the provider and payer aspects of healthcare. KeySys Health, LLC is a Birmingham, Alabama based healthcare consulting firm that specializes in working with small to medium sized clients to provide sound return on investment in the areas of EHR/EMR, regulatory compliance, revenue cycle management, branding and marketing. Contact us at 205.421.1700 for more ways we can help your practice succeed.

10 Things To Remember About Certified Medicare Rehab Agency Program Evaluation Compliance

1. Admit your mistake.  Do this in writing.  Identify this fault in your Program Evaluation Committee Minutes.  Send an email or copy of the minutes to your Governing Body so they are kept in the loop.

2. Show your plan for future compliance.

3. Never, Never, Never try to back date something.  Full disclosure is better than trying to hide something.  If you messed up, fine admit it and move on.  Just don’t let it happen again.

4. Don’t just attach a bunch of computer printouts to your Program Evaluation Committee Minutes.  This only proves one thing…you know how to use a binder clip!  CMS wants to know that you are providing real analysis.

5. Don’t get discouraged.  Program Evaluation is a snapshot of what you did clinically, operationally and financially during the past span of time.  It’s a systematic and overall.

6. Just because CMS asks for a “statistical analysis” doesn’t mean they want you to go into some statistical dissertation.  They only want you to analyze your data and use it to better your practice.  Remember, the rules are designed to look out for the Medicare beneficiary…. You know this person as “your patient!”

7. Don’t forget to include Policies and Procedures to support your Program Evaluation function.

8. Chart Reviews or Clinical Record Audits are NOT Quality Assurance; and NOT Utilization Review.  These are not interchangeable terms.  They have their specific scopes of concern.
Chart Reviews: This is Quality Control in making sure the construction and components of the chart are in place.  Example – “Is there an Initial Evaluation?”
Quality Assurance: This determines whether certain clinical requirements are followed.  Example – “Did the Initial Evaluation include an Objective review specific to the physician’s diagnosis?”
Utilization Review: This metric evaluates numbers of resources used in a Rehab Agency.  Example – Lengths of Stay, Visits per Referral or Salary Cost per Visit are good examples of Utilization Review.

9. Always use your Committee Minutes to support any questions or gaps.  This is a great place for “filler” that helps explain what you did (or didn’t do.)  Don’t just state facts or regurgitate data.  Explain it!

10. Develop a master calendar to show all your meetings.  Your CMS surveyor will be impressed that you are thinking ahead.  Remember, you may have forgotten to hold your meetings last year.  Why not start off this year with a plan and stick to it!

If you need help getting started, please review our free Program Evaluation templates.  Good luck with your Program Evaluation.  For further assistance on this or other Medicare certification compliance matters please contact Jeff Dance at KeySys Health. jdance@keysyshealth.com

Note on the author:  Jeff Dance has more than 20 years experience in Medicare certification compliance.  He has managed more than 2,000 certifications in all 50 states and consults with healthcare providers in all disciplines. KeySys Health offers a wide range of healthcare consulting services to small and medium sized practices.

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