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.

In the Spring of this year, I used baseball as a metaphor for the “game of Long Term Care.” At that time I said that providers were “going to have to step up to the plate and respond swiftly and powerfully to the curve balls of regulatory changes, the sliders of reimbursement, the change-ups of market pressures, and the fast balls of competition.” Little did I know at the time that the term, “sliders of reimbursement,” was going to be uncomfortably prophetic. Because of the drastic “adjustments” to Medicare reimbursement and declining Medicaid rates, the slider is real – a potential slide downhill, that is; they’re game changers. I would like to take the baseball metaphor one swing further.

A successful swing at the plate requires not only skills, talent, great vision, quick reflexes, good upper body strength, and sound judgment, but a solid bat as well, one that each batter can handle comfortably and confidently. It’s the tool that hitters rely on. In the case of LTC, the “bat” I am referring to is IT (information technology). And it’s time for IT to prove its worth as a tool to identify savings without cutting quality and to prevent unnecessary revenue leakage through automated tools and processes.

Savings – the IT Infrastructure

Let’s start with IT itself. Article upon article and one study after another have clearly identified that the “cloud” offers the scalability, flexibility, reliability, and savings that other methods of IT deployment may not offer. Cloud-based computing means lower initial costs and TCO, because all IT-related procurement, maintenance, management, and upgrades are handled remotely. Further, the cloud’s monthly subscription-based model enables providers to use their capital for other critical areas of their business. Earlier this year, the CIO Consortium identified that, “Reasonable, five-year costs to deploy currently available EMR technology and eliminate paper records range from $254,000 per facility for third party hosted solution (italics and color added for emphasis), $259,000 for vendor hosted Software as a Service (SaaS), and $356,000 for an in-house hosted solution.” Clearly, now is the time to carefully consider the cloud as a solid source for immediate and long-term savings.

Real Savings through IT Tools

What specifically does IT offer that will help providers identify savings, stop revenue leakage, and ensure that they are in compliance with regulations? The answer is automation - automated claims management to stop revenue leakage; automated MDS and RUGs reporting; automated procurement to make sure that purchases are per contract pricing, timing, and quality; automated labor management; and automated real-time Key Performance Indicator (KPI) reporting.

Automated claims management helps providers not only to generate, review, edit, and transmit claims, but to identify and act immediately on issues when and where they occur. This includes incorrect claims codes, codes changes and regulations, missing codes, poor communication between clinical and billing staff, poor pricing practices, and inefficient and ineffectual internal review processes.

Automated MDS and RUGs reporting lets providers identify facilities most "at risk" with poor survey performance; discover how each of their facilities ranks among its peers; pinpoint facilities which are operating below or above critical primary care staffing levels; detect residents/patients who are clinically at risk; observe the financial impact of MDS submissions by facility, region, and corporation; scrutinize QM/QI’s at a facility, region, or corporate level, and analyze reimbursement rates (RUGs).

Automated procurement involves complete commerce automation (purchase orders, invoices, and product and contract maintenance) and reporting with intelligent direction and feedback for procurement decisions.  It connects multiple facilities, satellite locations, and branch offices to the vendors, products, pricing, delivery terms, and service providers carefully negotiated and selected by their parent company. Automation allows flexibility and customization for each corporate entity to support their partner selection, the business rules negotiated with each partner, their internal G/L structure, and their purchasing chain of command.

Automated labor management gives providers the tools necessary to manage and control that which amounts to almost 60-70% of a provider’s spend – labor. Automation offers applicant tracking, time and attendance, payroll, and human resources management. Not only can providers reduce costs wisely, but also increase productivity.

Automated real-time Key Performance Indicator (KPI) reporting, or a digital dashboard, translates into business intelligence, which to LTC providers means they can quickly analyze and act on census levels, admissions, and discharges; labor hours and costs; and receivables and collections. Armed with this incredibly valuable information, providers are able to monitor how well they are saving money and increasing revenue in real time and take action, when necessary, with surgical precision.

Summary

IT through the cloud will not only help providers survive, but ultimately win, by confidently hitting whatever is thrown at them out of the park.