How to prepare for your next Medicare auditPublished: 2009-09-08 22:49:16Author: Kenneth Kei Adams | McKnight's | August 10, 2009Recovery Audit Contractors (RACs,) Medicare Audit Contractors (MACs,)
Fiscal Intermediary (FI) prepayment and post-payment audits, and Office
of the Inspector General (OIG) audits have been changing the face of
post-acute care for many years. With potential changes coming in
Medicare, there are important things that skilled nursing facilities
need to do to prepare themselves. It is not just about prevailing
through an audit—it is about improving patient care and improving
outcomes.
Since 2004 there have been more than 145,000 fewer
patients admitted to acute inpatient rehabilitation facilities (IRFs)
to receive their post-acute care.
i During that same time
period, there were over 400,000 more Rehab RUG (Resource Utilization
Group) assessments in skilled nursing facilities (SNFs).
ii This
is not just a switch from IRFs to SNFs; there are simply more patients
receiving their rehab in SNFs. This has been a boon for those
facilities geared to accept patients in need of physical, occupational
and speech therapy services.
During the last decade, Medicare
has begun to focus on pay-for-performance, value-based purchasing,
clinical practice guidelines and evidence-based medicine.
iii ivMedicare initially targeted hospitals and physicians and it is not
unreasonable to expect that post-acute care providers are next. Several
studies have suggested that therapy in SNFs does not produce the same
outcomes than in IRFs.
v vi In addition to the denials occurring
for medical necessity reasons, MACs and FIs have begun to look at
discharges to acute, patients that remain in therapy past 60 days,
patients that discharge to hospice and patients that do not discharge
home.
Many SNF providers have recognized the shift and are being proactive.
Medicare is demanding that attention be paid to both outcomes and
justification for providing therapy services. Nationally based
corporations such as RehabCare, Five Star Quality Care, Fundamental and
Nexion, as well as regionally based corporations such as Legend
Healthcare, and smaller local providers, including Presbyterian
Communities and Services and the Veranda at Preston Hollow, have begun
to implement strategies to address both outcomes and justification for
therapy as well as focusing on how to best appeal denied cases.
For
smaller, local providers, mounting a full-scale legal battle to appeal
denied cases can be both daunting and, in some cases, not fiscally
permissible. In a situation where 10 cases are denied at an average of
$200 per case, paying the Fiscal Intermediary back $2,000 is much less
expensive than hiring a legal team. Larger organizations such as
RehabCare and ManorCare have developed full legal departments.
RehabCare's in-house team with a lawyer and multiple other staff
members, has a current overturn rate of more than 90% (based on dollar
amount overturned per dollar amount denied).
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