Home Health & Hospice Week

Would your high-therapy episodes pass muster with the feds?

Every cloud has a silver lining, including the HHS Office of Inspector General audits of home health agency high-therapy cases.

Since last May, the OIG has issued three audit reports on HHAs that scrutinized episodes containing 10, 11 or 12 therapy visits. By breaking the 10-visit therapy threshold, agencies gain an extra $2,000 to $2,500 per patient episode. At least one more OIG audit on the topic is expected.

But agencies can expect the focus on episodes that just cross the therapy threshold to continue longer, warned physical therapist Cindy Krafft, director of rehabilitation for OSF Home Care based in Peoria, IL.

"If you look at the amount of money that has been recouped this way, I'm hard-pressed to believe" that the scrutiny won't continue, Krafft said in a recent teleconference sponsored by Eli Research, "OIG Audits for Therapy: Gauge the Impact and Prepare."

The first two of the three OIG audits, conducted in conjunction with regional home health intermediaries United Government Services and Associated Hospital Service, focused on therapy visits being medically reasonable and necessary, Krafft pointed out (see Eli's HCW, Vol. XIV, No. 21 and Eli's HCW, Vol. XIV, No. 28). "Documentation has got to reflect why you are setting up the plan of treatment that you are [and] what is reasonable based on what's going on with the patient," she stressed.

Don't Neglect the Basics

Sometimes therapists do a better job of documenting medical necessity and reasonableness when they are working in a less traditional area of therapy--incontinence, peripheral neuropathy, etc., noted Krafft, who is also vice president of the home health section of the American Physical Therapy Association.

With more usual therapy areas--gait for physical therapists, activities of daily living for occupational therapists, speaking and swallowing for speech therapists--"we need to make absolutely sure that we are not downplaying the skilled reason why we are in there," Krafft emphasized. "Some of those very basic ambulation, ADLs and communication may be streamlined out" during documentation time.

Tip: Therapists must be sure the frequency and duration of visits reflect the patient diagnosis, therapy goals and treatment plan to address reasonableness concerns, Krafft advised. If the frequency is outside the norm--say one visit per week, or five visits per week--be especially sure to document why it's called for.

Pitfall: Don't make the mistake of setting goals for the patient just for the goal's sake, Krafft warned. To cement medical necessity, you must tie goals to patient function.

Example: If you are showing the patient can walk 300 feet, how does being able to walk that distance change that patient's life? If she lives in an assisted living facility, maybe it means being able to walk to get meals. If the person lives in a trailer, maybe it's tied more to getting back into the community.

"That's what the documentation has to show," Krafft instructed. Document how often the patient is going to walk 300 feet and why that's important.

Use Chart Reviews To Your Advantage

HHAs can use chart reviews in a few different ways, Krafft suggested. First, you can internally review current charts for medically necessary and reasonable documentation.

Agencies sometimes have a difficult time reviewing therapy charts because their usual reviewers are nursing staff, Krafft noted. But they should realize that most external reviewers--OIG, RHHIs, etc.--will not have therapists reviewing the documentation either.

"It is important that non-therapy people can review your therapist's documentation and get a good feel for why the therapist is in there, what things they are working on and how they tie to function," Krafft said.

HHAs can also go back and review charts from the same time period the OIG has audited, 2001 and 2002, Krafft offered. While you can't fix errors you find in those charts, you can determine your risk if auditors come knocking on your door and learn lessons from the past to help with your future documentation.

Employ Audits As A Learning Tool

"It is critical to make your therapy staff aware of the [OIG] audits," Krafft urged. All your staff need to understand what is being scrutinized in these audits, so they can take extra care with their documentation.

Land mine: But don't let staff reaction hinder rather than help your mission. Therapists could think they should just avoid episodes with 10 to 12 therapy visits--or that they should never perform more than a handful of visits to patients because they can't justify them.

Emphasize that therapists' documentation needs to support why they are there, Krafft instructed. "Where is the functional goal, what is progress, what are the skill deficits of the patient and what are you doing to get there?" 

Note: To order a recording of the teleconference, which includes a therapy chart review tool, go to http://codinginstitute.com/conference/tapes.cgi?detail=404 or call 1-800-508-2582.