Medicare Compliance & Reimbursement

The feds are focusing on PAI documentation.

The patient assessment instrument (PAI) may seem little more than a thorn in a rehab provider's side, but it could wind up bringing the HHS Office of Inspector General (OIG) to a provider's door.

The OIG promised to take a close look at tardy inpatient rehab facility PAIs this year in its 2005 Work Plan, and providers can rest assured the feds won't stop there, experts note.

Lack Of Documentation Will Doom Assessment

"The OIG will be looking at the supporting documentation behind the assessments," predicts consultant Fran Fowler with Fowler Healthcare Affiliates in Atlanta.

Key ideas: The feds want to see how providers arrive at the numbers recorded on the PAI - especially the numbers that drive reimbursement, Fowler warns.
 
The PAI also should demonstrate rehab necessity, notes consultant Jason Levine with Murer Consultants Inc. in Joliet, IL. "You have to show how the patient is going to benefit from rehab," he reminds providers. The biggest problem providers have with their PAIs: The medical record documentation does not support FIM scores on the IRF-PAI.
 
Many facilities show a "considerable discrepancy between the numerical motor scores documented by nursing and those documented by occupational and physical therapists," notes consultant Ann Lambert Kremer with Beacon Rehab Solutions in Portland, ME.
 
And recording a score on the PAI that's not supported in the medical record is a no-no.

"It's okay if therapy notes don't exactly match nursing notes, but [therapists and nurses] do need to be looking at each other's notes," urges Fowler. "Often the notes are so different that they don't even appear to be describing the same patient," she says. "That's where difficulties occur."

Solution: Facilities with inadequate supporting documentation should "expand nursing, physical, occupational, recreational and speech documentation on initial assessments and weekly progress notes to include a brief narrative description of the patient's functional limitations," counsels Kremer. That way, the medical record will better support the data on the IRF-PAI, she says.