Ask the payment expert ... about the observation stay loophole

How can the Centers for Medicare & Medicaid Services correlate quality of care and reimbursement?

You always need to remember that Medicare is an insurance plan. As such, Medicare has rules, just like your insurance company. Two of those rules are that we must provide care according to an individualized care plan for each resident and that we provide appropriate discharge planning. 

A Feb. 27 OIG report gives an analysis on how providers are doing. The report says that 37% of all residents are not receiving appropriate care according to the care plan. Analysis would probably show that care plans are not our strongest process in facilities, but should be. 

Care plans must drive patient care. If the care plan is not complete, isn’t followed, or isn’t updated when needed, the entire care process is out of compliance. This is the reason you are cited for non-compliance during your survey. 

The report goes on to say that 31% of stays did not have adequate discharge planning. The OIG report recommends to CMS that it link payments more closely to quality of care. 

CMS also can fine your facility and place you on a monitoring process (corporate integrity agreement) because you are not providing appropriate care to residents. 

Bottom line: Teach your staff the care process, help them understand the importance of the care plan and discharge planning, and have an auditing process as part of your quality assessment process.