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Medicare Compliance & Reimbursement

REHAB:

Sound PAI Practices Can Make OIG Happy

Published on Fri Feb 25, 2005

Avoid these widespread FIM scoring errors.

The word is out that the Office of the Inspector General (OIG) is looking hard at tardy inpatient rehab facility assessments - and if the OIG's auditors come knocking, they'll want to see documentation to support each tardy assessment.

Providers should compare their patient assessment instrument (PAI) practices with this list of common FIM errors provided by consultant Ann Lambert Kremer with Beacon Rehab Solutions in Portland, ME. 

  •  Scoring too high on upper body dressing. A patient who suffered a hip fracture should not automatically be scored as independent (7) with upper body dressing. More often, the correct score for this patient will instead be a 5.
     
  •  Overlooking the distance the patient walks when scoring locomotion. Remember: The patient must walk a full 150 feet independently, and without sitting to rest, to score higher than a 5 on locomotion. If the distance is less than 150 feet under any circumstance, the highest that patient can score is a 5.
     
  •  Scoring too high on bladder management-level of assistance. This category includes complete and intentional bladder control, and any necessary equipment or agent use for bladder control.

    "If the patient has a device, we typically see that the nurse does all the care related to the device during the first three days of admission. In these cases, the correct FIM score would be 1," Kremer says. "Too often, we see this scored a 3 or 4."
     
  •  Misunderstanding what counts as an "accident" under bladder management-frequency of accidents. Providers should only consider a patient to have had an accident if he or she wets linens or clothing, including bedpan or urinal spills.
     
    "If the patient urinates into a Depends undergarment or a bed pad and the clothing or linens are not soiled," you shouldn't consider it an accident, Kremer instructs.
     
  •  Coding a resolved comorbid condition in PAI section 24. Providers should code a comorbidity unless it resulted in additional costs to the IRF.
     
  •  Coding a comorbidity without sufficient physician documentation. This scenario is particularly problematic if the comorbidity is driving payment, emphasizes Fran Fowler with Fowler Healthcare Affiliates in Atlanta. Providers should keep a sharp eye out for the following comorbid conditions, which physicians frequently fail to document adequately, Kremer says:
     
    278.01 - Comorbid obesity

    250.60 - Diabetes with neurological manifestations

    357.2 - Polyneuropathy in diabetes

    As far as payors and the feds are concerned, "if the physician didn't document [a condition], it doesn't exist," concludes Fowler.

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