Consumer Directed Services Budget Workbook Revisions to Accommodate Rate Changes for the CBA Program

The purpose of the letter is to provide direction to Financial Management Services Agencies (FMSAs) on updating Consumer Directed Services (CDS) employers’ budgets to accommodate the new payment rate, effective March 1, 2014, for Community Based Alternatives (CBA) Personal Assistance Services (PAS). The Health and Human Services Commission approved rate can be found in Information Letter No. 14- 16. The rate change for CBA PAS requires a service authorization change. By May 30, 2014, the … [Read more...]

Risk Reduction and the Internal Investigation Policy

An essential element of an effective health care compliance plan is the internal investigations policy.  Actions by employees, acting in the course and scope of their employment, can subject corporations to civil and criminal liability.  Detecting, investigating and remedying such situations are crucial given the regulatory environment under which health care companies operate. The conduct of the investigation itself can exacerbate the situation.  Employees subjected to discipline may … [Read more...]

RUG Reviews: The Exit Conference

http://youtu.be/aZNMNvHJYgc     At the conclusion of the onsite review, the HHSC-OIG nurse reviewer must hold an exit conference with the nursing staff.  The Administrator, DON, charge nurse and other leadership of the facility should attend in order to gain a full understanding of the findings by the nurse reviewer. The nurse reviewer is mandated to provide “formal written notification of all MDS validation findings during the exit process.”   You will receive a “List of … [Read more...]

RUG Reviews: Signing Documents Provided by the Reviewers

http://www.youtube.com/watch?v=gAJV7FsoXkg   During the exit interview of a RUG review, you will be asked to sign and initial documents.  It is very important that you understand what you are initialing or signing.  Carefully review the document that you are asked to sign and ask questions if you don’t understand it before you sign or initial.  These documents create a record that may become relevant in a Reconsideration or Appeal.  Let us discuss the details by first reviewing the … [Read more...]

YOUR RIGHTS DURING A RUG REVIEW

http://youtu.be/0My7cUQgW_w   What are your rights during a RUG Review?  It may be an overstatement to say that you have rights as the deck is so stacked against the provider and in favor of the OIG.  But, there are a few things to which you are entitled as part of the process of which you should be aware. First, the OIG is required to give you a letter upon entrance into your facility.  This is the signal that the review is beginning.  The letter will explain the procedures of the … [Read more...]

Three Ways to be Prepared for a RUG Review

  Your facility will have a RUG review in the near future.  Being prepared for a review can be half the battle.  Knowing  where all your old documentation is and knowing what, exactly, is in that documentation will make a RUG review much easier on the facility. There are three important steps the facility can take to not only mitigate errors found by reviewers, but create a far less stressful review.  Organization of old records is the primary key of your preparation.  Make sure a minimum … [Read more...]

CHARTING BY EXCEPTION–THE FAST TRACK TO RUG ERRORS?

  Charting by exception is the single most problematic form of nursing charting. Charting by exception is a tool used for residents who require little to no nursing intervention or care.   This type of charting, if not done correctly, will leave the facility subject to allegations of RUG review errors.  Reviewers scrutinize nurse charting to determine if it supports flow sheets and checklists.  Since MDS 3.0 requires clearly documented comments, charting by exception will be a basis for … [Read more...]

DRILLING DOWN TO ADL MDS ERRORS: THE HOW AND WHY MONEY IS WALKING OUT YOUR DOOR

  As discussed last week, ADL's are the major target for HHSC-OIG.  ADL's are the source for most errors resulting in RUG write downs.  Not only did the facility lose money on incorrectly charted ADL's they will also face large penalties after a RUG review.  Charting ADL's    For most MDS nurses, ADLS are pieces of paper the CNA's have scribbled some numbers on.  Ideally this number reflects both the Plan of Care and what care was really given.  Calculating an accurate ADL score for … [Read more...]

Rise of Accountable Care Organizations Changing the Landscape of Accreditation

According to a recent article in Modern Healthcare, increasing consolidation in the healthcare sector and changes in reimbursement methodologies, such as the payment structure for accountable care organizations ("ACOs") is leading to changes in accreditation standards. John Burke, the CEO and President of Accreditation Association for Ambulatory Health Care, stated, "The movement to accountable care organizations and other recent trends has led to more health systems reabsorbing primary-care … [Read more...]