Based on the OIG Audit Report: Financial Impact of Clustering Therapy Services During MDS Assessment Look-Back Periods for Texas Medicaid Residents of Long-Term Care Nursing Facilities, Texas HHS has issued a provider letter for Nursing facilities outlining best practices:
? Resident functional declines that do not warrant a significant change in status
assessment (SCSA) should be clearly documented in the clinical record to
support therapy evaluation and treatment orders.
? Therapy evaluation and treatment orders should have the appropriate
therapist and physician signatures.
?Therapy should be provided in the amount, duration and frequency as
reported on the most recent Minimum Data Set assessment (MDS). If there
has been a change in the resident’s therapy treatment plan since the most
recent MDS, this should be clearly documented in the clinical record
? Therapy treatment that is delivered at a different level than the physician’s
orders or the therapist’s orders, as noted in the individual’s therapy plan of
care, should be clearly documented in the clinical record to support the
change in therapy levels. This would include treatments that are increased
from a “3 times per week” to “5 times per week” interval during a look-back
period, along with a clear rationale for the increase.
And, even though the MDS RAI allows you to set the assessment reference date, OIG muddies the waters on that issue by having monitored the following practices:
? therapy provided at greater frequency only during the MDS lookback periods;
? therapy orders, to evaluate and treat, received just prior to MDS assessment