Kristy Brown

How do skilled nursing facilities, clinics and hospitals think about therapy? Focusing on patient satisfaction and revenue is a good start, but it is not enough. As therapy continues to be scrutinized more and more by the government and insurance companies, it’s a good idea for administrators, directors of nursing and compliance staff to become more familiar with therapy operations.

No matter whether therapy is provided by onsite staff or an external provider, care providers need to be familiar with compliance issues and policies. Therapy is now routinely audited by Medicare and other insurers. If something goes wrong, the clinic, hospital or skilled nursing facility where care is provided could be at risk. Therefore, it is the medical center’s responsibility to be sure it is compliant—not just the responsibility of the therapy company.

Here are some important questions that you should ask before you start any relationship with a therapy company:

  • What are your policies and procedures related to the area of compliance?
  • How does the department operate? What are the hours and days of service? What are the staffing levels? How many registered therapists are available and how many assistant therapists are present?
  • What is the philosophy behind the therapy company’s service model?
  • How does staff keep up with regulatory and insurance changes?
  • How does staff interpret changes to regulations?
  • What process does staff use for documenting their work with patients? Who monitors the documents and makes modifications to keep up to date with regulations if needed?
  • Is there an auditing system? Is the staff’s documentation routinely audited?
  • If people are not meeting the standards for audits, what is being done to help them?

While audits may take a bit of extra time, they help ensure a consistent approach to care that is in the best interest of patients and organizations.

I recommend that you make a policy and procedure manual available to therapists to be sure they aware of and are complying with everything you expect of them. Daily schedules, safety rules, standards of conduct for the clinic, policies and procedures should all be spelled out clearly.

Regulations change quickly and are subject to interpretation. You can make sure therapists and medical centers can keep up with regulatory changes and interpret them properly by joining professional groups or national organizations. Usually these organizations provide newsletters and educational training. Consultants can also help organizations who want the most current information available.

Here are some tips to help protect your organization from serious consequences related to noncompliance:

  • Know your service delivery methods inside and out
  • Know your therapists’ strengths and weaknesses
  • Make sure therapists know what is expected of them
  • Monitor communication/forms/accuracy
  • Work with outside contractors to enhance systems
  • Work with a compliance officer on staff or as a consultant to create a compliance plan
  • Perform audits
  • Familiarize yourself with Medicare’s local and national coverage policies
  • Access Medicare documents online concerning benefits and claims
  • Conduct daily Medicare meetings

The Takeaway: it is important to remember that it’s never too early to create systems and documentation to protect your organization from serious risk. The time to start is now.   


Kristy Brown is the CEO and President of Centrex Rehab. She is a speech language pathologist and has 20 years of management experience.