Latest / The Shift Ahead with Ken Bell / The Audit Risk SNFs Miss with Alicia Cantinieri
Transcript
- Ken Bell: The fallout can be really big if you're getting denied because your records are not being received on time. It's a hundred percent denial. I'm Ken Bell with Careability, and this is the shift ahead. Five minutes, three questions, and one expert, helping operators and clinicians prepare for what's coming next. Let's get into it. What audit or compliance risk are SNF leaders currently most likely to underestimate? ⁓ I think that SNF leaders ⁓ are most likely to underestimate the chances that they will be audited by one of the Medicare contractors. I also think that there's a definite lack of understanding about the Medicare contractors and what each of their missions is because they're not all the same and getting a letter from The you know the MAC routine post pay is much different than getting a letter from the UPIC. If there are errors, you may be able to appeal the recruitment, but you are not able to repeal your claims error rate. And that makes a big difference in the outcome of your audit. Leaders aren't aware of it in general because it's not taught anywhere, really. I mean, if you're a nurse, you don't learn that in nursing school. It's just something that you learn it's kind of on the job learning by experience, or if you attend a seminar where someone's talking about it. But otherwise, unless you do your own research, you're not going to find out. And a lot of times in that case, you don't know what you don't know. What's one practical step a facility could take now to find that risk that we're discussing before the audit does? Never a bad idea to do some internal auditing, just Pick a chart and kind of go through the process with it as though an ADR was requested. So everybody can go through the process with a little bit of less stress when they don't have a deadline. But either doing it that way, they can do have third-party audits. What you want is someone who's objective and only looking at what's in the medical record, not what they know about the resident, going through that. See how your process runs if you find a lot of hiccups along the way. then you know you need to evaluate your process and possibly make some changes to it. It's not enough just to say the resident has this condition or this treatment. We also have to support medical necessity in that record. And that goes all the way from the nurse who admits the resident through all the other disciplines, including therapy, including the medical team. Make sure that the person is chosen to be the ADR coordinator has the knowledge. And has the authority to really kind of lean on the team. If they have a piece that needs to be done, this is the deadline. And making sure that everyone does that and being the person that that ADR coordinator can go to, if necessary, to lean on the team a little more and make them understand how important that is. What do you think is the next big shift that healthcare leaders should be preparing right? Once the OIG completes a work plan, they publish their results. If it shows that CMS could have had some better oversight of the issue, then we typically end up in response with changed federal regulations or new federal regulations, which include new F tags, or they could be just updated F tags with more scrutiny by the surveyors. And it could be the Medicare contractors as well, depending on what the issue was. Everything is connected. So if the leader does nothing, that doesn't bode well for Medicare audits. It doesn't bode well for case mix audits if you're a case mix state. Doesn't bode well for survey, quality measures, five star. ⁓ so everyone needs to be aware and and that they are many things are connected in this industry. So if you're not doing well on one hand, you may not be doing well in in another area. I think that facilities can be most successful if From the the talk leadership on down, there's a culture of compliance. It's not how we do it because we might be audited. It's not how we do things because we will be in survey at some point. It's how we do things every day. We always document the medical necessity. We always document exactly what's going on with the resident. We document the communication with the physician. We make sure we always sign our flow sheets. We make sure that we're always survey ready. So that way when survey comes or a Medicare audit comes, we know that we have to gather those records. But we don't have to panic and worry about what the outcome is going to be if we're always doing everything the way we should do. We just gather the record, make sure we meet the deadline. And as scary as everything sounds, letters do come back from the contractor saying there are no fines.