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(November 2019 – Multiple requests on this topic)
Q: Can you provide information on the regulations for Restorative Nursing? I am specifically looking for information that approves Restorative Nursing and Therapy to occur simultaneously. We have always waited to refer to Restorative until after skilled therapy was complete. Our company is now requiring Restorative Nursing to begin on day 1 or 2 for our Part A admissions.
Answer: {We are posting the answer here for Members and Non-Members, as this question has been asked several times this month and the source document with the regulation is important for all SNF therapy professionals to read.}
The official reference to Restorative Nursing from CMS is in the RAI Manual.
The information is on page 531-533 and the primary information is in the excerpt below:
https://downloads.cms.gov/files/mds-3.0-rai-manual-v1.17.1_october_2019.pdf
- Restorative nursing program refers to nursing interventions that promote the resident’s ability to adapt and adjust to living as independently and safely as possible. This concept actively focuses on achieving and maintaining optimal physical, mental, and psycho-social functioning.
- A resident may be started on a restorative nursing program when he or she is admitted to the facility with restorative needs, but is not a candidate for formalized rehabilitation therapy, or when restorative needs arise during the course of a longer-term stay, OR in conjunction with formalized rehabilitation therapy. Generally, restorative nursing programs are initiated when a resident is discharged from formalized physical, occupational, or speech rehabilitation therapy.
“The following criteria for restorative nursing programs must be met in order to code O0500 on the MDS:
• Measurable objective and interventions must be documented in the care plan and in the medical record. If a restorative nursing program is in place when a care plan is being revised, it is appropriate to reassess progress, goals, and duration/frequency as part of the care planning process. Good clinical practice would indicate that the results of this reassessment should be documented in the resident’s medical record.
• Evidence of periodic evaluation by the licensed nurse must be present in the resident’s medical record. When not contraindicated by state practice act provisions, a progress note written by the restorative aide and countersigned by a licensed nurse is sufficient to document the restorative nursing program once the purpose and objectives of treatment have been established.
• 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. Sometimes, under licensed nurse supervision, other staff and volunteers will be assigned to work with specific residents. Restorative nursing does not require a physician’s order. Nursing homes may elect to have licensed rehabilitation professionals perform repetitive exercises and other maintenance treatments or to supervise aides performing these maintenance services. In situations where such services do not actually require the involvement of a qualified therapist, the services may not be coded as therapy in item O0400, Therapies or O0425, Part A Therapies, because the specific interventions are considered restorative nursing services (see item O0400, Therapies and O0425, Part A Therapies). The therapist’s time actually providing the maintenance service can be included when counting restorative nursing minutes. Although therapists may participate, members of the nursing staff are still responsible for overall coordination and supervision of restorative nursing programs.
- This category does not include groups with more than four residents per supervising helper or caregiver.”
- This item does not include procedures or techniques carried out by or under the direction of qualified therapists, as identified in Speech-Language Pathology and Audiology Services item O0400A or O0425A, Occupational Therapy item O0400B or O0425B, and Physical Therapy item O0400C or O0425C.”
(October 2019- OT DOR)
Q: If a resident dis-enrolls from a Managed Medicare plan to straight Medicare A, do we complete a 5 day assessment? In addition, would NTA (Non Therapy Ancillary) component triple for that period?
Answer:
(October 2019-PT DOR)
Q: We are being told by our medical coder and billing department that we cannot use R26.2 and M62.81 as treatment diagnosis because they cannot put these codes on the bill as they are “return to provider” codes and the bill will not be paid if there are ANY return to provider codes. Is this true? In light of all the changes is there a difference between medical and treatment codes now? Also, is there a difference in what codes we use for Med A versus Med B?
Answer:
(October 2019- Regional Rehab Director)
Q: When completing the Part A PPS Discharge MDS for a resident that crossed over from RUG-IV to PDPM – do we count the total minutes of therapy for the whole stay or just since October 1st under PDPM? Also, does the 25% limit on Group and Concurrent Therapy start October 1st or does is it retro to the start of therapy if prior to October?
Answer:
(September 2019 – PT/DOR)
Q: If we do not complete the BIMS or the Staff Assessment, how will we get a score? How will the cognitive level be determined?
Answer:
(September 2019 – MDS Coord/RN)
Q: Do we need to complete IPA’s for our non-Medicare Part A skilled residents for October 1st?
Answer:
(September 2019 – DOR, PTA)
Q: Does the ICD-10 Code we pick for Section I0020B on the MDS need to match the code we put on the billing claim? We review these at Triple Check?
Answer:
(August 2019 – DOR, PT)
Q: Please clarify when the SNF needs to issue a NOMNC (Notice of Medicare Non-Coverage) form for Medicare Part B residents.
Answer: Below you will find 3 references that support the answer.
(July 2019 – Jen OTR)
Q: I am looking for clarification on the Part A PPS Medicare End of Stay assessment. Is this only required if a resident is staying in the building and not being discharged home?
Q: And are we to be completing this for our managed medicare/commercial plans as well or strictly Med A only?
Answers:
(June 2019 – RP – DOR)
Q: Is an assistant allowed to report or change Section GG ? Can they fill that section out? Rationale is that if CNA’s can report then shouldn’t therapy assistants be allowed as well?
Answer:
(May 2019 – KM – DOR)
Q: I have an OT student who would like to be able to treat independently. I understand we both can’t treat different residents and bill as individual, but can you explain how to bill if she is doing a treatment while I am evaluating? Can the student treat a Medicare Part A resident while I evaluate another, and can we then both bill individually, or is this concurrent?”
Answer:
(April 2019 – Jenn – DOR)
Q: What will the minimum requirement for therapy be under PDPM? It is my understanding it can be 5 days a week, 30 min a day, which can be done by one discipline or split between disciplines. (ie: 2 days PT, 2 days OT and 1 day SLP)
Answer:
(March 2019 – DOR – Anonymous)
Q: I attended a seminar about PDPM and have a question. The presenter stated that the “facility would get paid for therapy whether it was provided or not.” Is this true? How does this work?
Answer:
(February 2019 )
Q/A: Due to the multiple PDPM (Patient Driven Payment Model) questions flooding in, we have created a 10 minute “crash course” video to help therapy professionals get their feet wet with the topic. Please see below….
Myths, misinformation and misconception…Seems to be a lot of this going around in the SNF setting these days regarding changes to come.
Here are the Top 5 Patient Driven Payment Model (PDPM) realities as we see them today…
- The new payment model begins in the SNF setting in less than 8 months
- Many SNF therapists voice they have received little to no information on the model that they can use in their day to day practice
- Many SNF therapists have not been able to do their own research on the model yet (And how could they?….No time to spare with {crazy} productivity requirements!)
- Many therapists are receiving PDPM information from their company and/or employer, and with that may come {some} bias
- A bulk of the information therapists are receiving is not completely accurate and is causing fear, panic and misconception regarding job security and professional duties.
SNF therapists want to do the right thing! That’s how they are wired!
Therapists are seeking accurate information about PDPM and we want to help. We recognize limitations in time and $ and wanted to be of assistance by giving SNF therapists a starting point where they can see and hear factual information about the PDPM changes to come, receive unbiased information and receive resources to further their education.
That’s why we created this 10 minute crash course video to get the ball rolling for SNF therapists. Now… with that said, no one who is serious about learning should ever get their full education from a crash course! This is just a starting point in which therapists are expected to build upon.
But you have to start somewhere, right? And 10 minutes of your day is not going to break you!
Watch the video….ask questions….do your own research!
We also have a “real” PDPM training course that can be found by clicking HERE This comprehensive course is 5 contact hours and includes case examples to calculate the PDPM vs RUG-IV payment rates. $149 for Members.
(January 2019 – Ryck – DOR)
Q: Are there any “free” resources out there to help with Section GG coding for Self Care and Mobility?
A: Yes! Here are a few to get you started.
CMS Training Video Series for Section GG
This is a “at-your-own-pace” training that goes through all of Section GG. Case examples are provided and you can code questions based on scenarios given, and then check your answers.
GG Self Care and Mobility Coding Decision Tree
This is a PDF 1 page decision tree to help you select the best answer for “helper assist” for all Self Care and Mobility questions.
SNF Quality Reporting Program Training Homepage – CMS
Section GG is part of the SNF QRP. The CMS home page is a good place to keep up to date on any new information released and/or review resources.
Article explaining SNF QRP and other Section GG factors new for 2019
Good Luck and if you have any questions, Just Ask!
(January 2019 – Deb – Billing Supervisor/Finance )
Q: We have just been notified that a few residents dropped their Medicare Advantage Plan on January 1st and switched back to traditional Medicare Part A. We want to bill Medicare for the days in January and need a PPS MDS to do so. Our MDS Coordinator is stating that she can’t create a PPS MDS now because it is too late. Please advise.
Answer:
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*Please note that when we receive multiple questions about the same topic (and we do!), we select one question and answer to post here to represent all questions submitted for that category. However, each Member submitting a question will receive a personal email response!
