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Is a clarification order needed for therapy services if we have an eval and treat order?

A clarification order is recommended after the therapist evaluates the patient, even if the order states “eval and treat.” The final rule is clear that the plan must be reduced to writing and reviewed by the physician. 

The clarification order serves as the physician approval of the plan. Without clarification orders, the Plans of Treatment must be signed and dated basically the day of the evaluation, which is not realistic in most settings.

If there is a delay with the signature, technically the minutes of care counted on the MDS can be reduced for the number of days the plan was unsigned. 

We have found situations where the fiscal intermediary has stated that clarification orders are not necessary. Having the clarification order ensures that the facility is meeting all the requirements.

What processes from the new MDS 3.0 can we begin to implement now?

Although the MDS 3.0 is still in draft form, the implementation of several new assessment tools will assist the facility in assessing the resident and some of the information can be utilized to evaluate the resident for answers to the present MDS 2.0.

One tool is the Patient Health Questionnaire (PHQ-7). This is a tool to assess depression and is utilized in other healthcare settings. It does a nice job in assessing the needs of the resident in everyday language. The guidelines for this tool also can assist your staff in identifying intervention needs.

The other tool that can be very useful is the PUSH tool. It evaluates the healing process of pressure ulcers and will be built into the pressure ulcer section of the MDS 3.0. 

Implementing that tool now as a part of your overall skin care management program will assist in meeting the requirements for F-314. 

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