You Asked – Experts Answered – 2019 Archive

Student, Individual or Facility Membership required to view the Answers  

Our Members say having their own “personal consultant” is priceless! 

(December 2019 – VP Op)

Q: Who can complete the BIMS (Brief Interview of Mental Status) for a Part A resident? Can a PTA or COTA?

Answer:

(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:

VIDEO:     Our PDPM 10 Minute Crash Course Video for SNF Therapy Professionals

(Not intended to be your only source of information….but enough to get you started!)