The TPE (Targeted Probe and Education) surveys are upon us.

Most of us will never see one; no doubt because we bill correctly every time. Stop laughing! But some of us will. If the TPE comes to you, it will consist of the Medicare Administrative Contractor coming to your facility and investigating your records and your claims.

Recently a skilled nursing facility in our area was at the business end of a review that found the following:

“RN assessment documentation for the initial assessment they had was not sufficient.

Per the MDS 3.0 RAI Manual and the CMS SOM:…. A resident may be started on a restorative nursing program when he or she is admitted to the facility with restorative needs, …when restorative needs arise during the course of a longer-term stay, or in conjunction with formalized rehabilitation therapy. The following criteria for restorative nursing programs must be met in order to code O0500:

  • Measurable objective and interventions must be documented in the care plan and in the medical record.
  • Evidence of periodic evaluation by the licensed nurse must be present in the resident’s medical record.
  • Nursing assistants/aides must be trained in the techniques that promote resident involvement in the activity.
  • A registered nurse or a licensed practical (vocational) nurse must supervise the activities in a restorative nursing program…. Nursing homes may elect to have licensed rehabilitation professionals perform repetitive exercises and other maintenance treatments or to supervise aides performing these maintenance services. … The therapist’s time actually providing the maintenance service can be included when counting restorative nursing minutes.”

Restorative is important. As we go forward, and into the Brave New World of Patient-Drive Payment Model (merely four months away), the importance and the weight of Restorative increases.

What’s interesting to note in the direct quotations from the review are the parts that mention “…in conjunction with formalized therapy” and “…licensed rehabilitation professionals…perform…exercises or other maintenance.” Have you heard the myth that restorative nursing can’t occur when therapy is still involved? Some nonsense about “duplication of services?” If restorative is performing a Walk-to-Dine program, it is NOT the same as the gait training that therapy is working on. If nursing is working on restorative dining, it is NOT the same as the swallowing therapy from speech. The duplication doesn’t exist.

PDPM will include a case mix factor for restorative. Nearly all short- and long-term residents benefit from restorative on a functional level, but the short-termers/skilled residents will benefit the facility from a financial aspect as well.

For those who are considering how to manage therapy in four months when they’re no longer using therapy as the primary revenue-producer, how about utilizing the therapy staff more for training restorative? Why not get a physical therapy assistant to be the point-person to ensure documentation from the restorative staff is being done and being completed competently? Ultimately a nurse needs to sign off on the plan and supervise, but who better than a therapist to modify and ensure the competency of the staff?

Over the years we’ve been experiencing the financial crunch, so we have considered our restorative programs disposable. That has to change as we go forward and as we ensure the most effective means of treating our patients and the most effective means of getting paid for it.