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 of two people are designated to do this as these will be the same people you assign to the Reviewers as document “pullers” and facility representatives during a review. Last, be prepared during the exit interview to ask all your questions, you will not get a second chance.
1. Consider Organizing Old Documentation.
Frequently, we will have facilities will give us documents after a review that would have stopped an error from occurring. We ask, where did you find it and commonly we are told, “Oh in a box stuck under a desk.” If your old charting is in disarray, you cannot give Reviewers additional documentation that supports your MDS billing claims. Refuting an error after the fact will be time consuming and can be costly. It is always better to stop the error than have to defend yourself.
The facility must organize and account for all older documentation. Facilities should designate a two (or more) person team to go through every old chart and make sure it is in order. This team should comb the facility for those old files and boxes that someone forgot in the back corner. Trying to do this while reviewers are in your building is impossible.
As an example, ADL’s are frequently targeted item by HHSC-OIG, The facility must be sure that all ADL flow sheets are in place and in order. We have frequently seen that ADL flow sheets are not dated or only have a month noted with no year. As you organize your charts, take note of issues like this and be prepared to support those poorly documented items with additional, appropriately dated, documentation. Knowing your weakness before it is exposed allows you time to gather and organize additional supporting documentation that may exist.
Make sure those records are complete and intact. If there are pages missing, look in file cabinets and old boxes. Do everything possible to make sure there are no missing documents and no date gaps. If you have missing documents, supporting documents from the same time frame can be used during a RUG review.
You cannot correct any entries, mistakes or missing documents. Supporting documents from the same time frame will be your only recourse during a review. It is imperative that every file be gone through, organized and made complete by the team. This will make the review process much smoother and go a long way to prevent RUG errors against the facility.
2. Organize a Team in Anticipation.
Why a team? When reviewers come to your facility they do so unannounced and will hand you a paper with 10 or 20 resident names on it. You will have 2 hours to produce all the documents that are requested unless those documents are in offsite storage.
By designating a two person team, one person will, most likely, be present when reviewers arrive at your door. This will ease the review process as the team will know exactly where everything is. Be sure your team is clear on the goals and that they have the authority to dig through all the old files and boxes.
Don’t expect that one MDS nurse can accomplish this task alone. The Reviewers are targeting a three year span from 2008 to 2010. Many of the records can be for residents deceased or no longer in your care. Many times these records are held both on and off-site. The facility will not understand exactly who the reviewers will target so the files that must be organized will be daunting. All those old file cabinets and boxes of unknown paper must be gone through with a fine tooth comb.
3. Know Your Rights and Be Ready to Exercise Them!
The facility must be familiar with all the rules governing a review and all of the rights they have during a review. We suggest you contact your attorney the moment the reviewers walk in your door if you are unsure of your rights.
Familiarize yourself with the review process before the reviewers arrive. Be clear on exactly what they are looking for and all of your rights. The facility representative interacting with the review team must know they have the right to be shown every error the reviewers find and be given the opportunity to find additional documents that support your original MDS coding. The facility also must know the person designated to produce the requested documents, only has two hours to present those documents unless the document is in offsite storage.
Usually, the facility has one person running around like crazy just pulling the documents the reviewers demand. This leads to lack of representation during the review process. Always have two people prepared to work through the review. One person must question every error the reviewers allege and be able to find addition supporting documentation that negates the error.
At the exit interview, question each item found in error. Ask why it was considered an error. This will be your only chance to question any findings. Read, carefully and completely, all documents the reviewers have you sign. Many clients have told us the reviewers never told them about errors nor were they given the opportunity to find additional documentation. However, they all signed documents stating they were given that opportunity and were told about every error.
A RUG review is an incredibly chaotic event that is several days in duration. There will be multiple reviewers all demanding documents at the same time from a single nurse. This is why a team is needed and the facility must be completely prepared for a RUG review. Prepare your old documents; prepare your team and the RUG review will go smoother and you may be able to avoid allegations of errors.
Next week, we will discuss your rights in fuller detail.
