1. THERAMAX THERAPY CO QUALITY ASSURANCE UPDATES/PROGRAM PLAN
Objective:1. To level off on understanding of Therapy Guidelines.
2. To be able to efficiently & effectively carry out plan of action towards an excellent QA program for Theramax.

2. REGULATION UPDATES ADR for Medicaid/Medicare providers
Therapy Visit Documentation scrutiny

3. What is ADR?
ADR is additional documentation requirements that Medicare or Medicaid or Private Insurance will require from the health care providers before the final/payment of the claim is processed. Mostly are denied. They can work back far as 3 years. Medicare already started, Medicaid in 2012 implementation.
Mandated by law through the recommendation of MEDPAC

4. ADR cont.
This program, created by the Affordable Care Act (ACA), will help identify and recover improper Medicare/Medicaid payments.
Recently through the senate investigation of the 4 major HHAs that there were proofs of over utilization of therapy to max out reimbursements.

5. More on ADR:
Medicare/Medicaid contracted third party: ZPIC,RAC,etc to do the audit.
Most auditors are RNs,PTs. They get paid based on the recouped money from providers.
Medicare/Medicaid installed a system that calculates error rate on billing or any electronic transactions: CERT for Medicare & PERM for Medicaid.

6. Therapy Visit Scrutiny, What is this
Therapy Visit Scrutiny, What is this? Auditors will look at notes based on:
Therapy care plan production should be based on the initial evaluation test and measurement.
When auditing for compliance with this requirement, find the clinical outcome goals (both short and long) on the therapy care plan, and work backwards to the corresponding therapy evaluation to find the tests employed to identify the baseline for this goal. If you can’t find the standardized test that produces your goal: you are out of compliance (HHSM news article, pub June 21,2011).
Baseline should be established at the initial evaluation.

7. What to watch during Notes QA?
All visit notes reflects the baseline established in the initial eval and poc.
In writing measurable progress goals should be clear & precise on the SOAP
Check if Therapist use Tinnetti Test,TUG & Gait Dynamic index test. Patient’s Gait is described.
as to stance, phase, velocity & protuberance.

8. More on what to watch QA:
Pain description should be described the pain & location, how does this interfere with ADLs task. Also include the measurable time minutes a patient able to perform a specific task.
Deviation of the frequency of the plan of treatment.

9. More to watch QA:
All visits should be covered with the plan of care and duly approved by MD on a timely manner. Reminder, No order per incident is major deficiency
Document in the visit note the WAY IT WAS ORDERED, otherwise we will be cited as having no order or orders not implemented.
All orders should be prepared in timely manner
Verbal orders should be signed by PT,OT,ST
PVO should be faxed within 24 hrs.
All MD orders should be signed and incorporated in the charts in 30 days of the order date. This is at the level of the HHA. For TTS patients, this rule applies.

10. Therapist Responsibilities:
Get additional orders for:
Major change in patient condition
Need of new discipline; new procedures
Changes in frequencies
Problems encountered with patients

11. Guidelines on Therapy:
Therapy services only provided by a qualified therapist in accordance with the plan of care.
Therapist evaluates patient when ordered, & assist MD in developing & revising POC that addresses patient’s needs.

12. TX Guidelines cont: Prepares clinical & progress notes:
notes are current, therapist documents patients progress towards goals & outcomes
Describe patient’s response to tx
Education to patient & family
In cases PTA are treating patients, PT should be readily available through frequent reporting, both verbal & written.

13. Guideline TX cont:
5. PTA shall not carry out TX which PTAs are not qualified.
6. PTA shall discontinue immediately any tx in cases procedure appear harmful to patients.
7.PTAs should not initiate or change of tx without prior assessment & approval of PT.
8.Therapist communicates with patient/family/physician & other discipline re: progress towards goals.

14. Guideline tx cont: Therapy participation in service programs
1. Clinical record-shows patient response to tx.
2. Coordination of TX with other skilled services.
3. Evidence of tx or equipment needs that are not addressed in the POC or communicated to MD. Red Flag
4. TX visits made at the frequency ordered.
5. Assessments/communication with other providers documented.

15. TX guidelines cont:
PTAs,OTAs that performs services are planned, delegated & supervised by therapist
Specific instructions to PTAs/OTAs must be based on prescribed POC, patient eval by therapist, and accepted professional practice. Therapists evaluate the effectiveness of services provided by PTAs/OTAs.

16. Guidelines TX cont:
Comprehensive Assessment completed only by qualified clinicians: PT/OT/ST.
Proof how does Therapist evaluate patient’s needs & responses furnished by PTAs/OTAs to measure patients progress in achieving outcomes.
Source: CMS Survey Protocol & State Operation Manual Pub. 02/11/11

17. QA Program Planning
Watchful for those very late notes, or else we will be out of compliance. State surveyors can report our therapists.
Use of Weekly Calendar Ledger during QA to help track correct frequencies of visits. If Kinnser don’t have this capability, we will formulate a template to help QA people.
Monitor all visits are covered with signed MD orders, specially TTS patient.

18. QA Planning continued:
Alert concerned Therapist for orders that needs to be done, e.g. deviation of visits, additional visits needed.
Coordinate care with involved skilled personnel of any issues/complaint arises, make sure to resolve it on a timely manner, ASAP no excuse for next day.
Maintain a complaint log & resolution documentation.

19. QA Planning cont:
Monitor all patient (s) in the In-patient facility e.g. hospital. Maintain a log. Notify all involved clinicians for any patient in the hospitals.
Ensure that therapy practices are sound, documentation is above reproach, and that we are doing the right thing and following the rules (Beacon Health publication Oct. 17,2011).

20. QA Planning:
QA staff will act as an internal auditors for therapy documentation.
Theramax will implement policy & procedure to strengthen Therapy documentation. (Update Form to MDs, use of Index test measurement).
Time Frame of Plan: November onwards.
Thank you.
LTG