Ask the payment expert ... about monitoring therapy services
Ask the payment expert ... about the observation stay loophole
What should an administrator do to monitor therapy services in his or her facility?
The main fact to remember is that you are responsible for what happens in your therapy department, even if you have a contract company.
First, you should observe what is happening in your therapy gym. If all of your therapy minutes being coded are individual minutes, observe to see if that is what is being provided. Individual minutes means that one therapist is treating one resident at a time.
Secondly, monitor to ensure technical requirements for therapy are being met. One of the most important: A physician must approve in writing the therapy plan of treatment (POT) prior to the plan being rendered.
So, if you have a therapy evaluation and treatment order on admission, you obtain a clarification order and you send the POT to be signed and if returns are timely, you are probably meeting this requirement. If not, you need to look at your practice to see if you are in compliance.
Thirdly, you need to make sure the therapy plan of treatment can stand up to medical necessity criteria. This is difficult, since medical necessity is defined. The best way to evaluate this is to ensure the level of therapy being provided is based on the prior level of function, diagnosis, and discharge location, taking into consideration residual effects of the illness or injury.
If you, as an administrator, do not feel you can effectively evaluate medical necessity, have someone do it for you.