Ask the payment expert ... about inaccurate MDS therapy information
What happens if my therapy company makes an error on the MDS and as a result, a change of therapy was missed? Are we still responsible?
You are responsible for any information on the MDS. You should, however, hold your therapy company responsible for accuracy of information on the MDS.
Make sure they are signing Section Z of the MDS. This holds them responsible for the accuracy of the information. In addition, you need to make sure any contract therapy agreement has an indemnification clause that holds therapy responsible if you have a denial.
Also hold them responsible for information that creates a billing error. The one thing to remember is that most indemnification clauses only hold the therapy company responsible for the amount you paid them if you have a denial. You would still lose your room and board coverage.
You are legally responsible for all information you submit for billing. Therefore, it is highly advisable that you have a triple-check process in place through which you are validating all the information on the bill prior to submission. That should include verification that needed Change of Therapy (COT) assessments were completed.
Another strategy is to have your MDS coordinator and therapy leaders talk daily to review any resident who has missed any therapy. They also should review anyone who is on their seventh day of the COT observation period to verify minutes are correct.