Home Health & Hospice Week

If your therapists have gotten sloppy with their documentation, they're not alone -- but now's  the time to rectify it. Requiring more detailed documentation of therapists as proposed in the prospective payment system proposed rule (see related story, p. 218) is a good idea in general, says physical therapist Cindy Krafft with consulting firm Fazzi Associates. For the most part, the new requirements "are things we should have been doing already," she says.

Thanks in part to computer-generated documentation templates on point of care software, therapists "have let the computer just speak for us," says physical therapist Sparkle Sparks, a consultant with OASIS Answers. The result can be generic documentation that makes it hard for auditors to figure out what's going on with the patient, let alone if visits are reasonable and necessary.

Staff shortages have led many HHAs to let poor therapy documentation slide, Sparks believes. "Home health agencies have done this to themselves," she says of the new requirements.

Good news: The increased documentation requirements should mean claims are easier to defend in medical review from intermediaries, ZPICs, or other auditors, Krafft expects. "It will be much easier to identify the medical necessity of the therapy services in the records," agrees Judy Adams with Adams Home Care Consulting in Chapel Hill, N.C.

Bad news: Because of the extra work involved in the new requirement, the number of visits therapists can make per day will be reduced. "That could result in less therapists being willing to work in home health," especially contract therapists, Adams expects.

"In many areas of the country and especially in rural areas, home health agencies are already struggling to recruit physical therapists," Adams observes. "This could make that process even more difficult."

Target: Therapy is a high-profile hot spot for the Medicare benefit right now. In addition to the PPS rule provisions, Senate and Securities and Exchange Commission inquiries are focusing on possible fraud and abuse related to therapy utilization. That means while the Centers for Medicare & Medicaid Services may tweak the therapy requirements, you can expect much of the roposal to stay intact in the final rule, experts believe. Basically the rule tells therapists to "document, document, document -- and document some more," Krafft jokes.

This is Medicare's wake-up call for HHAs and their therapists, Krafft emphasizes. "We have a lot of room to go" and you should get started on improving your therapists' assessment and  documentation skills today. Agencies "really need to start doing it now," she urges.

HHAs are battling reimbursement-threatening audits such as focused medical review right now, Sparks points out. They "already are in trouble" for poor therapy documentation.

Bottom line: Agencies should start improving documentation immediately, Sparks urges.