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Archive for the ‘Medicare Compliance’ Category

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 .

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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.

Take this quiz to see where you stand.
Roadmap for Compliance

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