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(December 2018 – Michelle OT/DOR)
Q: Who should be responsible for filling out Section GG of the MDS, therapy or nursing? Our therapy software populates the MDS from our evaluations but sometimes the MDS Nurse changes the data in GG. Are there specific rules around this?
A: Therapy vs nursing has been a debate since Section GG appeared in 2016, though training’s have always stated that Section GG data should not be based on 1 assessment, rather a compilation of the data and sources available to determine the resident’s “usual performance.” To emphasize their point, CMS provided additional language in the 10-1-18 release of the RAI Manual updates.
Here is an excerpt from the 10-1-18 Manual with red identifying new language added with this update:
Assess the resident’s self-care performance based on direct observation, as well as the resident’s self-report and reports from qualified clinicians, care staff, or family documented in the resident’s medical record during the three-day assessment period. CMS anticipates that an interdisciplinary team of qualified clinicians is involved in assessing the resident during the three-day assessment period. For Section GG, the admission assessment period is the first three days of the Part A stay starting with the date in A2400B, the Start of Most Recent Medicare Stay. On admission, these items are completed only when A0310B = 01 (5-Day PPS assessment).
Link the the RAI Manual HERE – Go to page 306 of 1517 to find the above quote.
Remember, the team has the first 3 days of the Part A stay to determine “usual performance” and code Section GG Self Care and Mobility Sections. During this 3 day window, there is ample time to obtain a history, interview the resident and/or family, review documentation and provide nursing and therapy assessments.
Assess the resident’s self-care performance based on direct observation, as well as the resident’s self-report and reports from qualified clinicians, care staff, or family documented in the resident’s medical record during the three-day assessment period
Just because therapy software can populate Section GG of the MDS from the initial evaluation does not mean this is how GG should be coded. Yes, the PT and OT evaluations will provide a great deal of insight into self care and mobility; however, a designated gate-keeper in the facility (typically the MDS nurse signing Section GG) should be comparing the therapy evaluation results with other sources prior to coding Section GG.
With PDPM on the way in 2019, it would be in the best interest of your SNF to designate specific staff to code Section GG vs accepting what pre-populates from therapy software. Section GG will determine the “Functional Score” in PDPM and input from the interdisciplinary team will be the best policy.
(December 2018 – Eric – SNF Outpatient Mgr)
Q: I understand that we will not need to use G-Codes for Medicare Part B therapy in 2019. My question is, does this apply to situations involving residents in a SNF receiving Medicare Part B therapy AND patients who come to the SNF’s outpatient clinic, or only outpatient?
(November 2018 – Denise – MDS Coordinator)
Q: We are trying to determine if there are specific requirements for signature dates on therapy evals and orders. We realize there are for Medicare Part B but what about for SNF residents?
(October 2018 – Bob – OT and Jess – DOR)
[We included both questions here as the topic was the same. The answer provided applies to both questions.]
Q: Can a therapy assistant do any part of the discharge summary or progress report? For example, can an assistant address the goals ?
Q: I was always taught that a COTA and PTA could write the subjective and objective part of a progress note. The assessment and modification of the plan needed to be completed by the PT and OT. Is this accurate for Medicare Part A and HMO?
(September 2018 – Misty – Rehab Manager)
Q: Who determines the frequency for physical/occupational therapy treatment for bundled payment patients in the SNF setting? Is the frequency dependent on the diagnosis for the episode?
(August 2018 – CB- Rehab Manager)
Q: When a resident in a SNF decides to go AMA, what are the therapist responsibilities as far as making recommendations and assisting the resident to the car on the day of discharge, etc.?
(July 2018 – Joanne – Rehab Director)
Q: Where exactly can I find where the OT/PT/SLP need to have their plan of care signed by the physician when treating under Medicare Part A? Does the Medicare Certification cover this?
(June 2018 – Kris – PT Manager)
Q: What is the rule/regulation regarding SNF setting and 3 days not being seen? What I’d like to clarify is if a patient is on PT and OT in a SNF, and a holiday falls on a Monday- would a PT and OT need to treat that person either on the holiday Monday, or once during the weekend to avoid 3 days of not being seen? Could only 1 discipline treat during that 3 day time or are all disciplines needed to treat?
(May 2018 – Valerie – Compliance)
Q: Regarding point of service documentation: Is it with-in reason to document during the patient’s rest breaks and shortly following the session in order to complete the visit and the documentation? Is this considered billable time? What about documenting an evaluation with several goals? If these goals are documented while the therapist and patient, and/or family members are developing the care plan together, would this be considered billable documentation time? Is there guidance on therapy documentation and billable time?
(April 2018 – Shelley – Manager)
Q: Do you feel the repeal of the cap has changed the use of the ABN’s?
(March 2018 – Lori DOR)
Q: Will only documenting total treatment minutes and CPT codes for each visit pass an audit for Medicare Part A? Where does it say that daily notes are needed for Part A?
(February 2018 -Geoff, PT Manager)
Q: Can you provide the latest update regarding the therapy cap and medical review process?
(February 2018 – Jen, Rehab Manager)
Q: Can our therapy orders have a frequency range? For example, 5-6 days per week? Our facility does this to allow flexibility with weekend coverage.
(January 2018 – Valerie – Auditor)
2 Part Therapy Cap Question:
Q1: When a patient is being seen under Part B in a SNF, if they meet their cap, is the documentation more likely to be scrutinized?
Q2: How does a clinician know when they are treating a patient beyond their cap?
(January 2018 – Donna PT- DOR)
Q: Can PTA’s and COTA’s write notes for patients on Med B?
(December 2017 – Kelly, DOR)
Q: For Medicare Part A, what are the rules for moving an ARD and for Grace Days? If a RUG is not met on the last ARD date, but was met the day before, can it be moved back a day or is this backdating?
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