Tips to focus your attention in October based on actual Proactive client pre-PDPM audit trends

You’ve followed the PDPM transition checklists. You’ve analyzed historic billing patterns and projected revenue shifts under the new model. You’ve trained extensively. You’ve honed the admissions and MDS data collection processes and updated various clinical meeting procedures to include discussions of functional measures, NTAs, modified diets and the like. You’re feeling (mostly) ready for PDPM.

As we meet the looming transition day next week that’s been circled in red on every SNF provider’s calendar for well over a year, we recognize there will likely be bumps on the road to PDPM mastery. However, remember our priorities are not changing. Quality care continues to reign supreme as the key focus of our work. CMS was clear during the recent QRP Provider Training that PDPM shines a light on care by reimbursing providers more directly based on individual resident care and service needs “Given the more holistic style of care emphasized under PDPM, program integrity and data monitoring efforts will also be more comprehensive and broad. For program integrity, we expect provider risk will be more easily mitigated to the extent that reviews focus on more clearly defined aspects of payment, such as documentation supporting patient diagnoses and assessment coding.” (Download SNF QRP Provider Training Resource here.)

As you prepare for the “real-life” conversion to PDPM, here are a handful of tips to focus your attention in October based on actual Proactive client pre-PDPM audit trends:

PDPM Audit Findings:

1) ICD-10 coding accuracy errors & lack of documentation to support active diagnoses
Proactive audit finding: Primary diagnosis is not supported in the documentation; daily nursing charting does not support skilled services related to the primary diagnosis selected as the reason for the skilled stay; no care plan or services documented to support active conditions that are coded and contributing to PDPM payment

2) Therapy plan of care lacks justification for the intensity/treatment type based on PDPM risks of underutilization
Proactive audit finding: no specific justification in therapy documentation for the treatment frequency/duration or mode of therapy

3) Section GG coding unsupported
Proactive audit finding: inadequate integration and documentation across the interdisciplinary team to support “usual performance” as coded; Charting to support Section GG function score is outside the lookback period, or there is not collaborative documentation from the interdisciplinary assessment for usual performance.

4) Missed opportunities related to Mechanically Altered Diets & Swallow Impairments
Proactive audit finding: occurrences of signs/symptoms of swallowing impairment during the look back period are not captured on the MDS; Diet change recommendations made by SLP/dietary the day after the ARD so not captured on the initial PPS assessment.

5) Daily skilled nursing care unsupported
Proactive audit finding: Missing or insufficient documentation of daily nursing skill and/or specific skilled interventions tied to individual resident conditions, co-morbidities, and the principal diagnosis

Last minute preparation strategies:

1) View the on-demand Transitional IPA webinar to ensure accurate conversion for residents continuing a SNF stay from 9/30 through 10/1. Click here to visit in our shop.

2) Schedule a remote coding and documentation audit in October to identify opportunities for improvement and ensure the best habits are forming for long-term PDPM success. Proactive’s PDPM experts offer remote audit solutions for coding and documentation compliance and reimbursement accuracy. Contact us today to learn more.

Proactive PDPM Resources

Webinar: PDPM Transitional IPA: Getting it Right! (Download here)
PDPM Section GG Function Scoring Competency Tool-kit (Download here)
PDPM Skilled Nursing Charting Guidelines (Download here)
Webinar: PDPM Skilled Nursing Supportive Documentation for Skilled Level of Care (Download here)
Cognitive Assessment Basics Tool-kit (Download here)
PDPM Audit Services (Learn more here)
Click here to see all PDPM resources in our shop.

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Blog by Amie Martin OTR/L, CHC, RAC-CT, President, Proactive Medical Review

Click here to learn more about Amie and the rest of the Proactive team.