
Combining scheduled and unscheduled assessments require the application of complex rules and effective systems to monitor the regular assessment schedule and the “rolling” COT 7 day look back periods simultaneously. The extra effort required can pay off in greater Medicare Part A reimbursements if you have the tools necessary to manage the process.
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A VP of Therapy Operations in Arkansas writes …..
“I reviewed the recent SNF PPS Clarifications Memo V1.1, dated March 2012 and would like to know how to best manage this issue. My greatest concern is selecting the correct ARD and thus preventing a lower “default” per diem reimbursement for Medicare Part A patients.”
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Other Medicare Required Assessment (OMRA) rules require therapists to monitor when “therapy isn’t provided” and to adjust ARD’s (assessment reference dates) and RUG’s levels based on the level and frequency of care provided rather than on the patient’s changing condition. Therapy may be missed on weekends, holidays, when patients refuse treatment or illness occurs, or during family visits. All of these situations challenge therapists’ ability to achieve consistent and optimum RUG’s levels for their patients.
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Therapists are responsible for compliance with the Correct Coding Initiative, the Medicare Part B Exceptions Process, and the 8 Minute Rule. These compliance regimens have complex guidelines on how “therapists” should apply modifiers or billing units to CPT codes provided. Missing modifiers or incorrect billing units are errors that will result in denials. These errors are costly both in terms of lost revenue and the time needed to research, re-bill, and recover that lost revenue.
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New CMS rules for Other Medicare Required Assessments (OMRA’s) go into effect on 10/1/2011. These rules place an additional burden on therapists to monitor when “therapy is not provided” and to adjust ARD’s (assessment reference dates) and RUG’s levels based on the level and frequency of care provided rather than on the patient’s changing condition.
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