Good care that is poorly documented can lead the feds to suspect fraud.

CMS is concerned that the prospective payment system includes financial incentives to provide more therapy than a patient needs, according to physical therapist Cindy Krafft, Peoria, Ill.-based consultant with Fazzi Associates.

To prevent that result, intermediaries focus intensely on the therapy documentation supporting the need for the visits provided.

Bottom Line: If you’ve provided six visits and the intermediary denies just one of them, your agency has lost $600, Krafft emphasizes. If the agency has already received the money for that episode, it must now return the overpayment. The most common reason for denial is that the visit was not medically necessary or did not require a therapist’s skills.

MO826 — how will it impact your therapy visits?  Find out in this AUDIO TRAINING EVENT.

The Heat Is On Therapy Documentation

Unlike the 2008 work plan, the HHS Office of Inspector General’s 2009 work plan does not specifically include a heading for home health therapy. But therapy services scrutiny is continuing and even expanding, says attorney Lucien Bernard with Pearson & Bernard in Covington, Ky.
If your average number of visits per episode has changed significantly this year, “you’d better be able to defend and justify the variance,” Bernard advises.

In looking at claims, the OIG asks if documentation supports services the home health agency is billing. Therapy notes must fit in with the rest of the record, both OASIS items and nurses notes. Inconsistencies will cost agencies because medical reviewers will not give agencies the benefit of the doubt, Krafft stresses. And be aware that a pattern of denials resulting from unintended omissions can look to the government like fraud.

Your Goal Is Revenue Retention

Problem: Good documentation is not just a nice extra to do if you have time. It is integral with the care you are providing, Krafft says. “Denials are usually not because a therapist said the wrong thing one time on one note,” she explained.

There is a pattern: An assessment that doesn’t really tell you what’s wrong; goals that don’t really tell you what the therapist plans to do; visits that don’t relate back to the plan of care; and repetitive visits with no clear reason for going.

Protect yourself: Intermediaries put resources into reviewing therapy documentation, and so should you, Krafft advises. In auditing records, Krafft usually finds that on at least 70 percent of the records reviewed, one visit must be removed. Often significantly more than one must be removed, with the average risk of $930 per record if they had been submitted unaudited, she reports.