Home Health & Hospice Week

Who is reviewing your therapy documentation?

One Medicare Administrative Contractor has reviewed nearly 12,000 claims and denied or downcoded many of them for therapy-based reasons. If you’re one of the home health agencies hit by these therapy-based denials — or just want to avoid being one — consider some expert advice by industry veterans:

1. Conduct therapy audits. HHH MAC Palmetto GBA has listed a variety of therapy-based reasons for its denials, including failing to set shortand long-term goals; documentation not supporting therapy medical necessity; and lack of measurement and assessment information in the record (see Eli’s HCW, Vol. XXVI, No. 20 for details on denial reason codes).

After educating therapists on the requirements, home health agencies “need to be doing therapy record audits routinely,” advises Judy Adams with Adams Home Care Consulting in Durham, N.C.

2. Follow up with audit feedback. It’s not enough just to find errors and fix them. You should use audit findings to give your therapists “timely feedback” on where their documentation falls short, Adams recommends. It’s important to do so individually, but you can also use common documentation errors you find as a basis for a more widespread inservice education topic. (For more therapy in-service topic ideas, see documentation tips in Eli’s HCW, Vol. XXVI, No. 21.)

3. Use therapists to review records. For many HHAs, the people responsible for conducting chart audits are nurses, and they do the therapy portions too. That can backfire, warns Julianne Haydel with Haydel Consulting Services in Baton Rouge, La. “One of the easiest ways to get documentation straight is to have a therapist review therapy notes,” Haydel says.

“If no therapist is available to review therapy notes, it may be an idea to bring in one to review notes monthly and pay them an hourly rate,” Haydel suggests. “This is a very good investment for agencies who have received denials.”

Review by the therapist is especially important for physical therapy aide documentation, Haydel adds. “When PTAs make visits, the therapist is supposed to supervise,” she stresses. “Agencies need to make sure that the supervision includes a review of the notes to ensure that what is reported is also documented.”

4. Consider corrections plans. If your therapists just won’t shape up after being educated oneon-one about their documentation errors, you may want to take it a step further: “Consider developing an internal corrective action plan if denials are continuing,” Adams offers.

“If you really want your plan to work, have the people who will be doing the work participate in the development,” Haydel urges. See Haydel’s other tips on CAPs at https://haydelconsultingservices.com/2015/01/02/writing-a-corrective-action-plan.

5. Check software, templates. Your software may be able to help your therapists to document correctly — but it also may put up roadblocks to thorough documentation, warns OT and consultant Karen Vance with BKD in Springfield, Missouri. “Since the way goals are determined is so dependent on the software, it’s not always an easy fix for agencies when they do get a denial,” Vance tells Eli.

Documentation templates can help guide therapists, but not if the therapists don’t fill out the forms correctly or adequately, notes Pam Warmack with Clinic Connections in Ruston, La.

6. Benchmark these therapy data points. If you’re seeing a lot of therapy denials, you may need to take a look at the whole picture and figure out if the services you are providing really are medically necessary, Haydel recommends.

Visits: “Agencies need to look at the number of therapy visits ordered,” Haydel tells Eli. “Some are ordering too many. They need to take a step back and order only as many as needed and be extremely conservative when the reassessments are due.”

One way to get at the question of necessity is to ask “what would happen if the patient didn’t receive additional therapy instead of how can they justify additional therapy,” Haydel offers.

Patients: HHAs also should examine the number of patients receiving therapy in their agency, Haydel says. “When a large percentage of patients receive therapy, the Home Health Compare ratings should reflect improvement in most of the ADL indicators,” she advises. “I frequently see clients that provide boatloads of therapy and their patients do not seem to improve to any great degree.”

The bottom line: “Who wants to pay for therapy if it isn’t doing any good?” Haydel asks.