Providers will benefit from moving beyond a billable minute or RUGs based therapy contract under PDPM

Therapy contracts are under review for many providers. In most cases, providers will benefit from moving beyond a billable minute or RUGs based therapy contract under PDPM. Most contracts are being bid based on a % of the PDPM therapy components (PT, OT, SLP),a % of the entire per diem, a flat rate per Medicare day, or per minute delivered.

As you begin contract negotiations, consider these talking points:

  • How will the vendor ensure consistent patterns of therapy provision as you transition from RUGs to PDPM? CMS will be monitoring provider patterns of therapy delivery and significant changes may result in medical review. Keep in mind that a vendor coming in significantly below their competitors on price may only be able to sustain those rates by sharply reducing the volume of services provided.
  • How will group/concurrent treatment be billed vs. individual therapy time under a billable minute or time based fee agreement?
  • What plans are in place to cover 7 day/week therapy including weekends and to provide prompt evaluations (e.g. to gather dysphagia and SLP co-morbidity information needed for Section K as well as other clinical data significant to PDPM reimbursement such as section GG)
  • Is there shared risk included in the arrangement so that the SNF and rehab vendor have joint motivation to drive quality care, ensure optimal outcomes, and capture appropriate reimbursement
  • What are the minimum productivity expectations for therapists and how is non-billable time (e.g. time spent in meetings, performing resident screenings, etc. ) addressed?
  • How does the contract address non-Medicare A therapy, the majority of which will not likely change significantly in October with the implementation of PDPM

Did you know Proactive’s therapy consultants can assist in managing your in-house therapy program, updating policies for PDPM, training teams, and in auditing/monitoring of clinical and reimbursement performance? Contact us today to learn more.

Services for Rehab Providers

As an independent consulting firm specializing in post-acute rehabilitation, our team assists contract therapy companies, in-house SNF therapy programs, and outpatient clinics manage compliance and medical review preparedness. Learn more here.

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

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