Question I know you covered this issue in your column before, but I still have some confusion. I know the recertification for Medicare Part B can be up to 90 days. Is the time interval the same for Part A certifications, or does Medicare require patients under a Part A SNF stay be recertified every 30 days?
Answer: Under Medicare Part A, the physician certification is for all of the services provided and is the responsibility of the facility to obtain. There is no separate requirement for therapy certification. The Part A timeframe for the initial certification is as soon as possible after admittance to the facility; recertification needs to be done by the 14th day and then every 30 days after that.
There is tremendous confusion over documentation for Part A SNF because, unlike Part B, Medicare has no regulations as to what is required. This is the same for inpatient rehab facilities. During the 1990s, most companies adapted the 700/701 forms for Part A documentation. Unfortunately, the 700/701 was written for Part B rules.
Under Part A, the therapist writes the plan of treatment/care for the length of time the therapist believes is required to achieve the long term outcomes. Once the physician has reviewed and approved the plan, there is no requirement for an updated POT to be sent to the physician, therefore "no requirement" for therapy recertification. The recertification would be obtained by the facility to cover all services being provided, not just therapy.
Fortunately, Medicare is in the process of working towards standardization of documentation requirements across all sites of service. This should certainly help lessen the confusion about documentation between sites of service.
Question: Could you tell me where to find the federal regulation that requires a quarterly screen on every SNF resident?
Answer: We can't tell you because there isn't any! There is no requirement by Medicare that screenings are to be performed in any of their provider sites. The quarterly screenings came about in the 1990s, when contract companies were paid by the number of hours their staff were in the facility. There were a lot of "additional" services provided, including quarterly screenings. It amounted to "trolling for patients," and there was probably a lot of therapy given to patients under Part B that was not medically necessary.
In spite of the fact that there is no requirement for screenings, the therapy staff is frequently required to perform them. If you perform screens, remember that a screen should be a hands-off review of the chart and possible discussions with the staff, and maybe the patient. The facility is required to do a quarterly MDS on each resident and this is an appropriate time for nursing to look at the medical record and see if a decline has occurred. If a decline has occurred and nursing service is unable to mitigate the decline, a request for a therapy evaluation may be warranted.
We are big proponents of nursing requesting an evaluation from therapy when the medical record identifies changes in the patient's condition that might need the services of a therapist. This should be occurring throughout the year, not just quarterly.
Pauline M. Franko, PT is owner of Encompass Consulting & Education, LLC; a consulting and education company specializing in Medicare Consulting, Compliance and Training, based in Tamarac, FL. The company's "Direction on Demand" service specializes in providing the rehabilitation professional with a clear, easy way to understand how to provide Medicare compliant services to their patients in the SNF and Outpatient settings. As an associate in Comprehensive Medicare Consultants, LLC, she is responsible for assisting with and directing compliance programs to Rehab Agencies. Danna Mullins is an associate and lecturer with Encompass. You may contact the authors through the Encompass website at http://www.encompassmedicare.com/ or by phone at 954-720-4087.