PDPM Top 10 To-Do List for September

1) Integrate PDPM processes for all new traditional Medicare Part A admissions; establish a plan to capture all unique patient conditions/characteristics for those with an anticipated discharge after September 30th.

Incorporate the CMS ICD-10 Mapping Tool into daily processes. Practice with new September admissions identifying the principle reason for the SNF stay, properly coding NTA items and SLP comorbidities. Fine tune ICD.10-CM coding procedures, and audit for accuracy and the presence of supportive documentation. Emphasize review of all diagnosis coding and charting for those residents anticipated to continue their part A stay into October.

2) Confirm PDPM readiness with software providers. Questions to ask: (1) What alerts will be available—e.g. RTP codes? (2) Will non-PDPM MDS assessments continue to be available for RUG based payers? (3) What coding search function/resources will be available? (4) What reporting options including outcomes tracking will we have access to? (5) What functions are available to assist with end of month reconciliation and billing?

3) Finalize systems for tracking interrupted stays—identify high risk residents who have the greatest potential to return to the hospital. Even residents admitted in September could fall under the interrupted stay policy if they return after 10/1/19 and within the interruption window. Keep in mind, this could impact scheduling of the transitional IPA.

4) Practice updated clinical meeting processes that incorporate IDT collaboration for PDPM factors such as, but not limited to: usual functional performance for proper coding of section GG, selection of the principal ICD.10 code, review of NTA conditions present, and identification of potential IPA triggers.

5) Double check that all RUG-IV required assessments have been completed on or before 9/30/19 to ensure proper billing; consider COT checks that may fall on 9/28,9/29 or 9/30—if a COT is identified, the COT OMRA must be completed. Start preparing to accommodate transitional IPA completion, including interim GG assessment and completion of the MDS interviews.

6) Optimize processes for identifying swallowing disorders – e.g. incorporate triggers for documentation related to signs and symptoms that suggest a swallowing disorder that has not been successfully treated or managed with diet modifications or other interventions; include review of SLP documentation

7) Business office training including use of new HIPPs codes, reconciling contract therapy invoices, and finalizing systems for the updated PDPM Triple Check process

8) Ensure therapy contracts are updated and confirm systems for tracking group/concurrent treatment information. Confirm staffing for last week in Sept, to capture rehab RUG prior to transition if reasonable.

9) Develop internal monitoring processes for PDPM risk areas and consider third party compliance audit services.

10) Update outcomes reporting, key performance indicator dashboards, etc. and assign personnel to oversee performance trends in areas such as functional improvement, therapy provision patterns, and group/concurrent treatment use.

If you have any questions about any of this information, please contact us.

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

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