Over the last several months, this blog has covered topics focusing on various aspects of IT and its impact on long term care. In our Thanksgiving Day blog, we observed how important IT has become to all of us – in how we work, how we communicate, how we entertain, how we educate, how we conduct business; IT is everywhere. Although slow in adopting technology, LTC providers have made significant progress in understanding, valuing, and embracing IT as a powerful tool to meet ever-changing challenges. For example, twice we demonstrated this fact as we momentarily digressed from IT-specific topics to alert readers about changes to billing therapy services to Medicare and avoiding workforce-related lawsuits.

These are trying and potentially dangerous times for the economy in general and long term care in particular. The vital role that IT can play in helping LTC providers survive reminds me of the African gazelle. The gazelle can reach a peak speed of 48-50 mph outpacing many of its predators. However, the cheetah can reach 0 to 60 mph in about 3.3 seconds with a top speed of 70 mph. You do the math. Since gazelles are a favorite meal for cheetahs, the difference between life and death is sustainability vs. spurts of brilliance. Cheetahs can only sustain such high speeds in bursts; gazelles on the other hand can maintain their top speed for miles. They can also make sharper turns and initiate quick changes of direction with minimal reduction in speed. Cheetahs cannot. Although slower, gazelles have the advantage if they are alert, sure-footed, and responsive to threats and opportunities.

Likewise, to survive and thrive, to outpace the “cheetah’s” of poor reputation, burdensome and sometimes conflicting regulation, competition, and reduced reimbursement, LTC providers must be on guard, quick to respond, and nimble. However, they also need vision. To blindly charge day-to-day into the fray without a clear understanding of what is going on around them and within their operations, can be suicidal. Data mining and business intelligence can help providers discover, discern, and act on the data they already have. In real time, digital dashboards can reveal business-critical information (Key Performance Indicators – KPIs) displayed in ways that easy to understand.

In 2011, we also discussed how important protection of your IT assets and data is and why disaster plans must include IT. “After the fact” is too late. Also, IT asset management (ITAM) can help providers to track and protect their IT assets, use, and storage.

Just over the horizon loom major changes in health care, ACOs being one of those changes. The significance of ACOs to IT in long term care can be found in the need for interoperability and IT infrastructure. Whether ACO’s pose a threat or an opportunity will depend on the specific market served and the provider’s willingness and ability to respond. Being uninformed and ill prepared is like a deer facing on-coming headlights. The prospect of becoming health care road kill is not appealing.

Question: IT is here to stay, are you on board? In what ways has IT helped your operation?

A recent article in the Nashville Post cited a lawsuit filed against a local nursing home by a former employee over lunch break pay policies. But, what does this have to do with IT?

A little background: As policy, some long term care companies automatically deduct 30 minutes from employees’ time worked to cover meal breaks even when the reality is that many are unable to take their full thirty-minute lunch break or habitually don’t take the full 30 minutes. As a result, facilities, like the one cited in the article, No lunch leads to lawsuit, are exposed to potential legal action.

Some employees don’t get to take a lunch break or are not allowed to because of the workload. (Interesting to note, some conscientious employees object to having to rigorously adhere to taking a full 30-minute meal break, because they want to be back on the floor and not let work get further behind. Just sitting around for the full thirty minutes is torture to them.) If a facility automatically deducts 30 minutes for a meal break, management needs to monitor this carefully to make sure that employees indeed take their lunch break.

The ramifications of a decision in favor of a plaintiff could be significant. If the court found the facility in violation of the law, the facility would have to pay the plaintiff for meal breaks not taken. Further, the plaintiff’s attorneys in the above-referenced case are seeking a class-action status for the complaint. That means the facility may have to pay wages owed to all staff who didn’t fully take their meal breaks, possibly even if they are no longer employed by the facility. The cost to the facility for such a decision not only would include the back wages owed and legal fees, but also the time and expense required to audit payroll records as stipulated by the court.

• Are you automatically deducting 30 minutes for a meal break?
• Are your employees taking the full thirty minutes? Are you sure?
• Does your Time and Attendance application enable you to manage meal breaks?

If you are not certain or there is room for reasonable doubt, call PCT. We can help you find a solution that will help you to monitor this and ensure compliance with applicable state laws and the Fair Labor Standards Act. Certainly, you should consult your HR specialists and legal counsel regarding your existing policies and best practices.

I know it’s late in the day and many of you are already heading to your turkey feast destination or making last-minute preparations, but I think expressing gratitude is never too late - or too early for that matter. First, if not for the vision, talent, dedication, and hard work of so many, we would not enjoy the explosion of opportunities that information technology offers us. Whether it’s for entertainment, checking on one’s health, mining data, checking on the weather or road conditions, tracking finances, operating a business, promoting ideas, products, and services, or just meeting or reconnecting with friends, IT is everywhere. Some may argue that IT may have complicated our lives, but in the long run, our lives, our play, our work, even our worship have been positively impacted and enriched. For this, we should be very grateful.

Further, our PCT’s team expresses our sincerest gratitude to our customers and partners. We have seen phenomenal growth over the last year and without them, we could not be where are today and will be going forward.

Lastly, to our team members, thank you for your dedication, hard work, and sacrifice in serving our customers and supporting one another. That’s what makes this company work.

Happy Thanksgiving!

Billing Medicare Part A for Ancillary Therapy Services - a change in what units represent

Focusing on Medicare’s coverage and payment for ancillary therapy services, Transmittal 2239 (CMS Manual, Pub 100-04 Medicare Claims Processing, issued June 14, 2011, Billing SNF PPS Services, 30.4 - Coding PPS Bills for Ancillary Services) states, effective August 1, 2011, “For therapy services, that is revenue codes 042x, 043x, and 044x, units represent the number of calendar days of therapy provided.  For example, if the beneficiary received physical therapy, occupational therapy and speech-language pathology on May 1, that would be considered one calendar day and would be billed as one unit.” (Italics added.)

In other words, for each day a Medicare patient receives a therapy service, providers must record that as one unit. In the past, the number of units reported on a claim reflected the number of treatments provided. That is no longer the case. The new policy stipulates that units of therapy should tie to the number of days the patient received therapy services, NOT the number of treatments. For codes 042x, 043x, and 044x, providers are to record the total number of days a resident received therapy treatments as one unit for each day. Providers can look at this as an “on/off switch,” “yes or no” answer. Did the resident receive PT today? If, “yes,” then record 1 unit. If a resident had 16 days of physical therapy treatments, for example, the 042x revenue code should indicate 16 units. The aggregate of the total units/days of therapy services received would be recorded on the claim. 

The transmittal further stipulates that “SNFs are required to report the actual charge for each line item, in Total Charges.” The total should reflect the charges for actual treatments received as determined by your facility’s/company’s charge master and recorded in the Total Charges field.

Questions

If you are using a clinical software application for documenting therapy services, does it automatically convert days of service to units to be recorded in aggregate on the claim while recording the charges based on the quantity of treatments?

What changes were necessary for you to comply with this regulatory change?

With the hiring of Ms. Becky Bos and Ms. Kimberly Kelly, PCT offers enhanced Revenue Management Consulting Services to long term care providers. Cuts in Medicare and Medicaid services have forced providers to effectively maximize and capture the revenue they are able generate. Becky and Kimberly have extensive experience and expertise in working with large multi-facility corporations and small regional providers to identify and collect the cash owed. This is the first in a series of articles in which Becky and Kimberly share their collective wisdom regarding sound billing and collection practices providers can employ.