Greater flexibility is good news for SNFs

Beginning 10/1, up to 25% of therapy may be provided as group and/or concurrent treatment per discipline. Greater flexibility in how care and services may be delivered to Medicare patients is good news for SNFs, but keep in mind that the 25% group/concurrent treatment is a ceiling and not a target.

Key take aways as you apply the updated Group Therapy rules:

  • CMS has been clear that they will monitor provider behavior to determine appropriate use of group therapy and will assess dramatic shifts in provider behavior
  • The 25% will be tracked based on the Discharge MDS which will include a look back of therapy minutes/days and mode for the entire stay. We recommend including group/concurrent modes of treatment as part of the plan of care as clinically indicated, and establishing processes to monitor treatment time spent in non-individual therapy.
  • The proposed rule has defined a group as 2-6 patients, which would be a change from the current RAI definition of 4 patients. Stay tuned for the final group to therapist ratio to be clarified.
  • In preparation for PDPM, we suggest development of group policies and procedures and treatment protocols.
  • Continue to track modes of therapy weekly –going over the 25% designation will result in a non-fatal error, but patterns of overage may result in medical review

Contact Proactive for policy templates, group therapy training and PDPM auditing and monitoring services. Watch for our group therapy toolkit coming soon!

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Blog by Stacy Baker, OTR/L, RAC-CT, CHC, Director of Audit Services, Proactive Medical Review

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