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Six steps to therapy billing compliance

Rehab Regs, October 17, 1999

Published: October 2000

Therapists should not be surprised that the government is scrutinizing therapy claims for improper billing in skilled nursing facilitie, says Karla Dreisbach, director of quality and compliance for Brandywine Senior Care, a regional nursing home chain in Exton, PA.

Dreisbach, who directs the compliance efforts for 12 facilities in the Mid-Atlantic region, provides the following recommendations to help ensure proper therapy billing:

1. Establish a clearly defined denial review process. If a therapy bill is unjustly denied, an appeals process should be in place. Without a denial review process, facilities could end up with a backlog of denials that result in financial losses. It can also help facilities to learn from their mistakes. "You can better understand why you're being denied so you can correct the problem or get clarification from the fiscal intermediary [FI]," Dreisbach says.

2. Proper documentation. As the saying goes, "If a service isn't documented, then it wasn't provided." Therapists need to clearly identify their thought processes in documentation. Dreisbach recommends that therapists attend seminars and workshops. Talk with FIs about documentation guidelines for Medicare and Medicaid. In addition, therapists should be aware of what's considered skilled services, and what's considered maintenance or restorative. It will help ensure that here is a clear understanding of what is billed as a therapy service and what is billed as nursing. It's also important that documentation is legible.

3. Perform a quarterly screen of patients for therapy needs, functioning, and progress. Quarterly screenings of residents helps identify quality of care and medical necessity issues. Screenings also help promote good documentation for assessment and services.

4. Establish a systemwide auditing system for therapy. The process should monitor clinical/medical record documentation, therapy minutes provided, medical necessity, and the correlation to billing.

5. Create communication channels between therapy, nursing, and the billing office. Whether communication is verbal or written, staff members should be discussing the status of residents, the services being delivered, and changes in condition. Some facilities bridge the communication gap by holding daily, brief "stand-up meetings," in which staff members, including the billing department, review these issues. Other facilities create a simple written communication form that is routed through the building.

6. Establish a compliance program. A compliance plan should be in place to guide staff members, including therapists, on policies and procedures for billing and documentation. Additionally, there should be a system in place that allows staff members to report improper billing. It should be clear that there is no retribution for reporting improper billing.

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