Compliance Corner

Compliance Corner

Compliance Corner

2016 MSCA Process Updates and the Importance of Medicare Meetings

Ironically, the old adage that does not change in healthcare is “The only thing that is constant is change.” Year two of the IRO on-sites is now over, and there is always a lot we can take away as an organization from these audits. Oftentimes, it makes us reflect upon the processes that we have in place in both operations and compliance, and how effective they are in preparing our facilities for success.

With that said, there will be some tweaks in the works for the 2016 MSCA compliance auditing process to help capture where we may be vulnerable and also to mimic the process of IRO on-sites more closely. Also, one of the areas we always focus on but that still needs constant fine-tuning is our Medicare Meeting and how we, as an organization, can be better. A question you may want to ask yourself when looking in the proverbial mirror is, “How can I be better?”

MSCA Process Updates

The MSCA process for 2016 will remain relatively the same in terms of the number of audits and the types of things we will be auditing. One of the things that will be changing is how we select some of the claims we will be auditing. The biggest change with the claims selection process comes with our “High Risk” facilities. We will still have a split audit for these buildings, but for the first portion of the audit, we will use Length of Stay reports found in PCC to help guide the claim selection process. This makes sense, as we know and have learned (sometimes the hard way) that our claims with longer lengths of stay are the most vulnerable.

The other things that are changing are the additions of therapy treatment observations and DOR interviews during the on-site portions of the MSCA. This will closely mimic what is done during IRO visits and will help us not only prepare for possible IRO selections, but also help us at the facility level to identify possible root-cause weaknesses in our processes. Your compliance partners will inform their facilities of the changes and will be happy to go over these new processes with you and your facility teams should there be any questions.

Importance of the Medicare Meeting

The Medicare Meeting is always an emphasis to look at and improve upon, even in the best of our meetings. This year’s IRO on-site helped us identify some areas where we can definitely improve not only as an IDT, but as DORs.

For one, make your voice known. We found yet again, the best meetings were the ones where IDT members were fully engaged and challenging each other, asking the right questions about patient care, discharging of therapy disciplines, appropriate lengths of stay, etc. So, what if you notice your IDT members are relatively quiet or things are going a little too smoothly and everyone agrees completely with everything? Ask yourself if all the right questions have been asked and key factors have been analyzed regarding the patient’s care. Take the onus and help engage your fellow IDT members if need be.

The improvement in use of standardized testing was great to see and was noticed by the IRO. However, let’s not lose sight of the fact that our IDT members may not be as well-versed in these tests as you may be. Take the time to help educate and explain to the team what these tests are and how the scores impact the patient. The more they know, the more relevant the information and conversation you will have with standardized testing.

Finally, we all have full days and run busy programs, relying greatly on our therapy staff to support us. Gathering information from the therapy staff about resident care is vital to providing pertinent information during the Medicare Meeting. I think it’s safe to say that we all do that in one form or another, but how sure are we the information we are providing during the Medicare Meeting is being captured in the actual therapy documentation? Unfortunately, it was a hard lesson learned this year, that that situation can occur. So I ask all of you not to rest on your laurels and your past successes, but rather to re-evaluate your current systems to answer the question, “How can I be better?”