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Now that the final rule has been published for the inpatient rehab prospective payment system (PPS), rehab providers will need to develop education and training programs that will show staff how to assess, document, and maintain or improve quality under PPS.
Everyone from hospital coding staff to therapists to physicians will need to know how PPS reimbursement works and how a facility can be certain to receive the proper reimbursement.
Hospital-based rehab facilities should consider identifying one coding expert to work with rehab charts rather than continuing to rely upon the general medical record staff to do the coding work for rehab PPS, suggests Carolyn Zollar, JD, vice president for government relations at the American Medical Rehabilitation Providers Association in Washington, DC.
"I’m hearing from clinicians and coding experts that it’s sometimes like blind people describing an elephant because they all see something different," Zollar adds. "So you need one consistent person for the rehab perspective."
Here are some other staff education and training tips:
• Teach staff impact of PPS on reimbursement and length of stay (LOS).
Management at Crozer-Keystone Health System in Upland, PA, held meetings with staff about how inpatient rehab PPS would impact the facility’s LOS. Staff training covers the appropriate documentation of patient function, verifying and validating consistency in what is reported about the patient’s function during the first two or three days, determining appropriate codes, and taking data from the correct sources, says Bonnie Breit, MHSA, OTR, administrative director of rehabilitation services.
"There will be training and assurances that all of our existing systems can work with whatever CMS puts out," Breit says.
Staff training at Schwab Rehabilitation Hospital & Care Network in Chicago has been under way since the spring, says Laura Landmeier, OTR, MSOT, MBA, assistant vice president of quality and outcomes management.
"We’ve brought things in the staff’s attention in a slower manner," Landmeier says. "We bring it up and then reinforce it, moving on to the next step as we’re ready."
Landmeier sometimes provides some of the education at team meetings, giving staff a brief overview of PPS. During the less formal training sessions, staff can bring up questions and issues about how PPS would work in a particular situation, and Landmeier can then answer them either individually or in a group setting.
Training also includes inservices and educational memos, as well as quick e-mail notes in answer to an employee’s question.
• Orient staff to case mix groups.
It’s important to show staff how one omission or mistake in assessing a case mix group category could result in a greatly reduced reimbursement, notes Joe Golob, PT, director of the inpatient rehab center at Bon Secours St. Francis Health System in Greenville, SC.
"It is amazing how much difference one point score could make in some of those case mix groups," Golob says. "A score correctly identifying a lower-functioning spinal cord patient could make a difference of $12,000 in reimbursement."
Rehab facilities have always tried to be accurate with assessments, but the scoring has never had the financial impact it will have under PPS, Golob adds. "I think we’re conveying that message ongoing to staff."
Schwab Rehab staff need to understand that when a patient is admitted, the staff should begin to think of the patient in terms of case mix group and functional level, Landmeier says.
"We need to bring them along a path that is appropriate, but rehab isn’t a cookbook, so it’s important that everyone is educated on the system, knows the rules and regulations, and keeps sight of the individual within the system," Landmeier adds.
• Educate physicians about comorbidities and coding.
"One of our biggest educational pieces will be educating and reminding physicians of the importance of listing all clinically relevant comorbidities that affect the treatment and the care of the patient," Breit says.
"We’ll do a combination of education at staff meetings, inservices, and through written documentation, providing memos and copies of the rules," Breit adds.
Landmeier has spent several months attending medical staff meetings and providing education in small doses.
"Also, at team conferences we can do individual education concerning an individual case and team with the doctor present," Landmeier says.
Physicians are key players in documenting comorbidities and making certain the coding is done accurately, she adds.
"We’ve also been working with the medical records staff to make sure we get the coding done up front and to keep communication between clinical groups and medical records flowing efficiently and smoothly," Landmeier says.
• Hold a dry run of how cases would look under PPS to assess staff training and coding process.
It’s important to educate staff about how and when the test run will be conducted, and a dry run should involve taking case samples from rehab units or focusing on a specific rehab team, Landmeier says.
Managers at Crozer-Keystone will begin a process of evaluating, looking at cases, redoing documentation, and checking accuracy, Breit explains.
"Obviously, we’ll need to carefully assess the situation before we’re impacted by actual payment," Breit says. "One of the advantages the industry has right now is that there are several companies out there offering tools to provide this assistance."
For some facilities, such as the rehab unit at Bon Secours St. Francis Health System, there will be an automatic "dry run" period because of their fiscal year cycle.
"The fortunate thing for us is that we have an eight-month window in which we’ll have to start submitting data on patients on Jan. 1, but we won’t actually be paid based on those instruments until September 2002," Golob says. "So hopefully we’ll have the bugs worked out by then."