Medicare Madness 2014: What You Need to Know

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FY 2014 is under way and providers continue to struggle to provide quality care in an audit climate. The key to Medicare compliance is understanding the requirements. This presentation overviews the trends in the Skilled Nursing Facility (SNF) industry related to the provision of quality Medicare services. The presentation also covers the recently released Centers for Medicare and Medicaid Services(CMS) and Office of Inspector General (OIG) announcements, reports and manuals impacting the provision Medicare of services in a Skilled Nursing Facility setting. Learn what is happening with the JIMMO Settlement as the CMS January 24th deadline has passed. Are you ready to receive your next PEPPER report? Are you ready for ICD-10? What is the OIG 2014 work plan? Harmony Healthcare International (HHI) summarizes the need to know information to ensure providers are prepared for FY2014.

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Medicare Madness 2014: What You Need to Know

  1. 1. March Medicare Madness: What You Need to Know HARMONY UNIVERSITY The Provider Unit of Harmony Healthcare International, Inc. (HHI) Presented by: Kris Mastrangelo, OTR/L, MBA, LNHA President and CEO Keri A. Hart, MS-CCC/SLP, RAC-CT, CHHRP-QT Vice President of Clinical Operations/Education and Training
  2. 2. Harmony Healthcare International, Inc. 2 About Kris Kris Mastrangelo, OTR/L, MBA, LNHA Kris Mastrangelo, President and CEO, owns and operates Harmony Healthcare International, (HHI) an industry leader in Long Term Care consulting. 14,000 Medical records reviewed per year Core Business Patient Centered Follow Me! @KrisMastrangelo Copyright © 2014 All Rights Reserved
  3. 3. Harmony Healthcare International, Inc. 3 About Keri Keri Hart, MS-CCC, SLP, RAC-CT, CHHRP-QT Keri Hart is the Vice President Clinical Operations/Education and Training at Harmony Healthcare International, (HHI) an industry leader in Long Term Care consulting. Over 25 Years Experience in Long-term Care Rehabilitation Management MDS Follow Me! @CHHRPHart Copyright © 2014 All Rights Reserved
  4. 4. Harmony Healthcare International, Inc. 4 March Madness Disclosure: The planners and presenters of this education activity have no relationship with commercial entities or conflicts of interest to disclose Planners: Elisa Bovee, MS, OTR/L Diane Buckley, BSN, RN, RAC-CT Keri Hart, MS-CCC/SLP, RAC-CT, CHHRP-QT Presenters: Kris Mastrangelo, OTR/L, MBA, LNHA Keri Hart, MS-CCC/SLP, RAC-CT, CHHRP-QT Copyright © 2014 All Rights Reserved
  5. 5. Objectives The learner will be able to: Identify CMS and OIG documents impacting Medicare in a Skilled Nursing Facility (SNF) Discuss the importance of the PEPPER Discuss the impact of delays in Medicare appeals process Discuss highlights of the 2014 OIG Work Plan Harmony Healthcare International, Inc. 5Copyright © 2014 All Rights Reserved
  6. 6. SNF PEPPER
  7. 7. SNF PEPPER TMF Health Quality Institute has announced that effective January 1, 2014 it will no longer resend copies of SNF PEPPERs (version Q4FY12) which were initially mailed to all Skilled Nursing Facilities on August 30, 2013 Harmony Healthcare International, Inc. 7Copyright © 2014 All Rights Reserved
  8. 8. SNF PEPPER The next SNF PEPPER (version Q4FY13) will be distributed in late April – early May 2014, and will be available for access in an electronic format by the Skilled Nursing Facility’s CEO/ Administrator/President TMF will send an email notification when the Q4FY13 SNF PEPPERs are available In order to receive this notification, facilities must sign up for notifications on the TMF website Harmony Healthcare International, Inc. 8Copyright © 2014 All Rights Reserved
  9. 9. PEPPER PEPPER gives provider-specific Medicare data statistics for services vulnerable to improper payments Allows providers to see how their facility compares to all other SNFs across the state, nation or Medicare Audit Contractors(MAC) jurisdiction. PEPPER data is also shared with both Medicare Audit Contractors (MACs) and the Medicare Recovery Auditor Contractors (RACs) Harmony Healthcare International, Inc. 9Copyright © 2014 All Rights Reserved
  10. 10. PEPPER Expect the report to include the following comparative data: Therapy RUGs with High ADLs Non-Therapy RUGs with High ADLs Change of Therapy Assessment Rehab RUG Utilization Rehab Ultra High Utilization 90 Day+ Episodes of care Harmony Healthcare International, Inc. 10Copyright © 2014 All Rights Reserved
  11. 11. Take Away Nuggets Ensure you are signed up to receive access to your SNF PEPPER Review with the Team Obtain a Harmony PEPPER Analysis Harmony Healthcare International, Inc. 11Copyright © 2014 All Rights Reserved
  12. 12. Jimmo v. Sebelius Settlement Agreement
  13. 13. Jimmo v. Sebelius Settlement Agreement CMS Released updated Fact Sheet (December 2013) “Jimmo v. Sebelius Settlement Agreement Program Manual Clarifications Fact Sheet” Released pursuant to the terms of the Jimmo v. Sebelius Settlement Agreement CMS must have completed manual revisions and “educational campaign” by January 23, 2014 Harmony Healthcare International, Inc. 13Copyright © 2014 All Rights Reserved
  14. 14. Jimmo v. Sebelius Settlement Agreement Also CMS has “decided to use this opportunity to introduce additional guidance in this area, both generally and as it relates to particular clinical scenarios” CMS Webinar complete December 2013 and is available at http://www.cms.gov/Outreach- and-Education/Outreach/NPC/National- Provider-Calls-and-Events-Items/2013-12-19- Jimmo-vs-Sebelius.html Harmony Healthcare International, Inc. 14Copyright © 2014 All Rights Reserved
  15. 15. Jimmo v. Sebelius Settlement Agreement Revised portions of the relevant chapters of the program manual used by Medicare contractors to Clarify Skilled Nursing Facility (SNF), Inpatient Rehabilitation Facility (IRF), Home Health (HH), and Outpatient (OPT) Coverage Pursuant to Jimmo vs. Sebelius Transmittal 176, dated December 13, 2013, is being rescinded and replaced by Transmittal 179, dated January 14,2014 to correct an error in Chapter 8, Section 30.4.1.1.was sent to http://www.cms.gov/Regulations-and Guidance/Guidance/Transmittals/Downloads/R179BP.pdf Harmony Healthcare International, Inc. 15Copyright © 2014 All Rights Reserved
  16. 16. Jimmo v. Sebelius Settlement Agreement The revisions in Transmittal 176 incorrectly indicated that skilled physical therapy services in the skilled nursing facility (SNF) setting must “…require the skills of a qualified therapist (not an assistant) for the performance of a safe and effective maintenance program.” The regulations under 409.32(a) and (b) do not specify that an assistant cannot perform maintenance services in the SNF setting, unlike the home health and outpatient regulations which do make that distinction. Therefore, this updated transmittal corrects that particular language to eliminate the phrase “(not an assistant)”. Harmony Healthcare International, Inc. 16Copyright © 2014 All Rights Reserved
  17. 17. Take Away Nuggets Ensure all Staff responsible for making Medicare Coverage Determinations read Chapter 8 of the Medicare Manual Review JIMMO Webinar provided by CMS Therapist Review of Chapter 15 Medicare Part B Update Harmony Healthcare International, Inc. 17Copyright © 2014 All Rights Reserved
  18. 18. Centers for Medicare & Medicaid Services (CMS) revised Chapter 8 “Coverage of Extended Care (SNF) Services Under Hospital Insurance” with implementation on January 7th 2014 Copyright © 2014 All Rights Reserved Harmony Healthcare International, Inc. 18
  19. 19. Overview of Changes Chapter 8 "Medicare Benefit Policy Manual" (MBPM) now clarifies key components of SNF coverage requirements pursuant to the settlement agreement in the case of Jimmo v. Sebelius Also CMS has “decided to use this opportunity to introduce additional guidance in this area, both generally and as it relates to particular clinical scenarios” Harmony Healthcare International, Inc. 19Copyright © 2014 All Rights Reserved
  20. 20. Overview of Changes The revised Chapter 8 now includes a new section (30.2.2.1) titled “Documentation to Support Skilled Care Determinations” which details the role of appropriate documentation in “facilitating accurate coverage determinations” for claims for skilled levels of care Harmony Healthcare International, Inc. 20Copyright © 2014 All Rights Reserved
  21. 21. Improvement Standard “Improvement Standard” is not to be applied in determining Medicare coverage for maintenance claims in which skilled care is required Medicare has long recognized that even in situations where no improvement is expected, skilled care may nevertheless be needed for maintenance purposes (i.e., to prevent or slow a decline in condition) Harmony Healthcare International, Inc. 21Copyright © 2014 All Rights Reserved
  22. 22. Importance of Chapter 8 This manual is the source document for making skilled coverage decisions and ensuring documentation supports the care provided Requirements detailed are for skilled rehabilitation and skilled nursing services Source document utilized by Medicare reviewers in detailing why a claim for skilled rehabilitation or nursing services is denied Harmony Healthcare International, Inc. 22Copyright © 2014 All Rights Reserved
  23. 23. Medicare Benefit Policy Manual, Chapter 8 (2014)-Rehabilitation Daily Single type of skilled rehabilitation every day, or by furnishing various types of skilled services on different days that collectively add up to “daily” skilled services. “Arbitrarily staggering the timing of various therapy modalities though the week, merely in order to have some type of therapy session occur each day, would not satisfy the SNF coverage requirement for skilled care to be needed on a “daily basis.” To meet this requirement, the patient must actually need skilled rehabilitation services to be furnished on each of the days that the facility makes such services available.” 23Harmony Healthcare International, Inc.Copyright © 2014 All Rights Reserved
  24. 24. Take Away Nuggets Skilled Chart Reviews Interdisciplinary Documentation Process Review Ensure all Staff responsible for making Medicare Coverage Determinations read Chapter 8 of the Medicare Benefit Policy Manual Ensure daily skilled therapy requirements met (actually need skilled rehabilitation services to be furnished on each of the days) Harmony Healthcare International, Inc. 24Copyright © 2014 All Rights Reserved
  25. 25. RAI Manual/FY2014 Changes Harmony Healthcare International, Inc. 25Copyright © 2014 All Rights Reserved
  26. 26. Final Rule On August 1, 2013, the Centers for Medicare & Medicaid Services (CMS) published the Final Rule for the Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities (SNF) for FY 2014 Effective October 1st, 2013 for FY 2014 RAI Manual (November 05, 2013) JIMMO Settlement Language, Section O (Sept) Harmony Healthcare International, Inc. 26Copyright © 2014 All Rights Reserved
  27. 27. Distinct Days of Therapy Add MDS Item 00420 (Calendar Days of Therapy) Distinct calendar days of therapy Clarify that classification criteria for the Rehabilitation Medium RUG categories require that the resident receive 5 distinct calendar days of therapy (3 Low) If not achieved, the RUG would reduce to a Nursing RUG Applies to COT review and Management Harmony Healthcare International, Inc. 27Copyright © 2014 All Rights Reserved
  28. 28. Final Rule Increased Lower 14 RUGs Increased Nursing RUGs with Therapy involved Clarification on Open Door Forum that COT Process Stops when RUG is Non- Therapy due to insufficient Minutes and days to meet a category Potential Default if completed when not required Harmony Healthcare International, Inc. 28Copyright © 2014 All Rights Reserved
  29. 29. Take Away Nuggets Utilize Short Stay Policy Ensure COT Rules are applied per Clarification Provide RAI User’s Manual Section to Dietary, Therapy, and Social work to ensure instructions are followed Harmony Healthcare International, Inc. 29Copyright © 2014 All Rights Reserved
  30. 30. OIG Report: “Skilled Nursing Facilities Often Fail to Meet Care Planning and Discharge Planning Requirements”
  31. 31. OIG Report February 2013 OIG Report “Skilled Nursing Facilities Often Fail to Meet Care Planning and Discharge Planning Requirements” This study is part of a larger body of work about SNF payments and quality of care 31Harmony Healthcare International, Inc.Copyright © 2014 All Rights Reserved
  32. 32. OIG Study Based this study on a medical record review of a stratified simple random sample of SNF stays from 2009 Sample of 190 stays that projects to 1,104,692 stays in the population 83 stays in which the beneficiaries were discharged to another institutional setting Reviewers determined the extent to which SNFs developed care plans that met Medicare requirements, provided services in accordance with care plans, and planned for beneficiaries’ discharges as required Harmony Healthcare International, Inc. 32Copyright © 2014 All Rights Reserved
  33. 33. OIG Findings In 36.7 % of stays SNFs did not develop care plans that met requirements or did not provide services in accordance with care plans In 31 percent of stays SNFs did failed to meet discharge planning requirements Medicare paid approximately $5.1 billion for stays in which SNFs did not meet these quality-of-care requirements Reviewers found examples of poor quality care related to wound care, medication management, and therapy Harmony Healthcare International, Inc. 33Copyright © 2014 All Rights Reserved
  34. 34. Percentage of Stays in Which SNFs Did Not Meet Discharge Planning Requirements, 2009 Discharge Planning Requirement Percentage of Stays in Which SNFs Did Not Meet Discharge Planning Requirement Summary of beneficiary’s stay and status at discharge 16.0% Post-discharge Plan of Care 23.3% Total 30.9% Harmony Healthcare International, Inc. 34 Note: The rows do not sum to the total because some stays did not meet either requirement. Source: Office of Inspector General Medical Record Review, 2012 Copyright © 2014 All Rights Reserved
  35. 35. Discharge Summary The discharge summary should include: Summary of the beneficiary’s stay Beneficiary’s status at the time of discharge Post-discharge plan of care When a SNF anticipates the discharge of a beneficiary to another care setting or home, it must plan for the discharge The SNF must develop a discharge summary to help ensure that the beneficiary’s care is coordinated and that the beneficiary transitions safely to his or her new setting Harmony Healthcare International, Inc. 35Copyright © 2014 All Rights Reserved
  36. 36. Post-Discharge Plan of Care Post-discharge plan of care: Describe what the beneficiary’s and family’s preferences for care are How the beneficiary and family will access these services How care should be coordinated if continuing treatment involves multiple caregivers Education or instructions Harmony Healthcare International, Inc. 36Copyright © 2014 All Rights Reserved
  37. 37. OIG Quality of Care As part of the medical record review reviewers identified examples of poor care that that they determined to be egregious: Based solely on a medical record review Does not identify all instances of poor quality care Reviewers did not systematically review the records for poor quality care provided during each stay Harmony Healthcare International, Inc. 37Copyright © 2014 All Rights Reserved
  38. 38. OIG Poor Quality Care Wound care Developed Pressure Ulcers Provided inadequate wound care and neglected to provide interventions aimed at relieving pressure Developed additional pressure ulcers Worsening pressure ulcers Did not include detailed information about wounds in the medical records SNFs may not want to call attention to any pressure ulcers acquired during a beneficiary’s stay for Quality Measure reporting Harmony Healthcare International, Inc. 38Copyright © 2014 All Rights Reserved
  39. 39. OIG Poor Quality Care Medication Management Given an antipsychotic drug during her SNF stay. This drug has a “black-box warning” that it is not approved for patients with dementia-related psychosis and may result in severe or life- threatening risks Given an antipsychotic drug when she did not have a diagnosis for psychosis and her care plan did not indicate that she had a mood disorder Harmony Healthcare International, Inc. 39Copyright © 2014 All Rights Reserved
  40. 40. OIG Poor Quality Care Therapy Provided inappropriately high levels of therapy to beneficiaries given their conditions SNF provided a hospice patient with physical therapy 5 days a week for 5 weeks. The medical record showed that the beneficiary participated in therapy at first, but at some point, she did not want to continue. However, the SNF continued the therapy at the same intensity for the remainder of her stay until she was discharged to home with hospice care. A patient dislocated a hip and could not bear weight on that side. Even though the beneficiary should not have been ambulating, the SNF provided “ultrahigh” levels of physical therapy to the beneficiary for the entire stay. Harmony Healthcare International, Inc. 40Copyright © 2014 All Rights Reserved
  41. 41. OIG Poor Quality Care The OIG Linked the care plan to contributing to care provision that that they determined to be “egregious” Harmony Healthcare International, Inc. 41Copyright © 2014 All Rights Reserved
  42. 42. OIG Findings These findings raise concerns about what Medicare is paying for SNF oversight needs to be strengthened to ensure that SNFs perform appropriate care planning and discharge planning https://oig.hhs.gov/oei/reports/oei-02- 09-00201.pdf Harmony Healthcare International, Inc. 42Copyright © 2014 All Rights Reserved
  43. 43. OIG Recommendations Centers for Medicare & Medicaid Services (CMS): Strengthen the regulations on care planning and discharge planning Provide guidance to SNFs to improve care planning and discharge planning Increase surveyor efforts to identify SNFs Link payments to meeting quality-of-care requirements Follow up on the SNFs that failed to meet care planning and discharge planning requirements or that provided poor quality care Harmony Healthcare International, Inc. 43Copyright © 2014 All Rights Reserved
  44. 44. Take Away Nuggets Prepare for Focus on State Survey Prepare for Focus on Medicare Part A Reviews Ensure Care Plans meet Requirements Ensure Discharge Process includes a Discharge Summary Post-discharge plan of care Expect CMS to “link payments to meeting quality-of-care requirements” Harmony Healthcare International, Inc. 44Copyright © 2014 All Rights Reserved
  45. 45. The Department of Health and Human Services (HHS) Office of Inspector General (OIG) “Strategic Plan for Fiscal Year 2014”
  46. 46. OIG Strategic Plan January 31, 2014 The OIG Strategic Plan focuses on four goals: Fight Fraud, Waste, and Abuse Promote Quality, Safety, and Value Secure the Future Advance Excellence and Innovation http://oig.hhs.gov/reports-and- publications/archives/workplan/2014/Work-Plan-2014.pdf Harmony Healthcare International, Inc. 46Copyright © 2014 All Rights Reserved
  47. 47. OIG Strategic Plan SNF Medicare Part A billing by skilled nursing facilities Policies and Practices: We will describe SNF billing practices in selected years and will describe variation in billing among SNFs in those years CMS has made substantial changes to how SNFs bill for services for Medicare Part A stays Harmony Healthcare International, Inc. 47Copyright © 2014 All Rights Reserved
  48. 48. OIG Strategic Plan SNF Questionable Billing Patterns for Medicare Part B We will identify questionable billing patterns associated with nursing homes and Medicare Part B Providers in Nursing Homes Therapy and Medical Services (2014) Harmony Healthcare International, Inc. 48Copyright © 2014 All Rights Reserved
  49. 49. OIG Strategic Plan SNF State agency verification of deficiency corrections Quality of Care and Safety OIG will determine whether State survey agencies verified correction plans for deficiencies identified during nursing home recertification surveys (2014) Harmony Healthcare International, Inc. 49Copyright © 2014 All Rights Reserved
  50. 50. OIG Strategic Plan SNF Program for National background checks for long- term-care employees Review the procedures implemented by participating States for long-term-care facilities or providers to conduct background checks on prospective employees and providers who would have direct access to patients and determine the costs of conducting background checks Determine the outcomes of the States' programs and determine whether the programs led to any unintended consequences (2017) Harmony Healthcare International, Inc. 50Copyright © 2014 All Rights Reserved
  51. 51. OIG Strategic Plan SNF Hospitalizations of nursing home residents for manageable and preventable conditions Determine the extent to which Medicare beneficiaries residing in nursing homes are hospitalized as a result of conditions thought to be manageable or preventable in the nursing home setting Hospitalizations of nursing home residents are costly to Medicare and may indicate quality-of- care problems in the nursing homes (2014) Harmony Healthcare International, Inc. 51Copyright © 2014 All Rights Reserved
  52. 52. OIG Strategic Plan-MAC Ensure Part A and Part B claims are paid correctly. MACs are responsible for developing, inputting, and turning on local edits within their jurisdictions, as well as evaluating the effectiveness of medical review edits Review benefit integrity activity performed by Medicare benefit integrity contractors in calendar years 2012 and 2013 Safeguard the Medicare program against fraud, waste, and abuse Harmony Healthcare International, Inc. 52Copyright © 2014 All Rights Reserved
  53. 53. Information Technology Security, Protected Health Information, and Data Accuracy We will review independent evaluations of information systems security programs of Medicare fiscal intermediaries, carriers, and MACs Medicare and Medicaid contractors and at hospitals for security of portable devices containing personal health information Harmony Healthcare International, Inc. 53Copyright © 2014 All Rights Reserved
  54. 54. Medicare Secondary Payer Improper Medicare payments for beneficiaries with other insurance coverage Medicare as Secondary Payer Identify Medicare payments made for services to beneficiaries who have certain types of other insurance coverage to assess the effectiveness of Medicare’s controls to prevent such payments Harmony Healthcare International, Inc. 54Copyright © 2014 All Rights Reserved
  55. 55. Take Away Nuggets Prepare for additional Medicare Part A and B reviews Review process for meeting Medicare Secondary Payer requirements Review HIPAA requirements Analyze your hospitalization and re-hospitalization rates and analyze Harmony Healthcare International, Inc. 55Copyright © 2014 All Rights Reserved
  56. 56. ICD-10 Codes
  57. 57. ICD-10 code On October 1, 2014, the ICD-9 code sets used to report medical diagnoses and inpatient procedures will be replaced by ICD-10 code sets The transition to ICD-10 is required for everyone covered by the Health Insurance Portability Accountability Act (HIPAA) Note, the change to ICD-10 does not affect CPT coding for outpatient procedures and physician services Harmony Healthcare International, Inc. 57Copyright © 2014 All Rights Reserved
  58. 58. ICD-10 code CMS ICD-10 resources Tools Planning Implementation Videos Talk Ten Tuesday Podcast http://www.cms.gov/Medicare/Coding/I CD10/Latest_News.html Harmony Healthcare International, Inc. 58Copyright © 2014 All Rights Reserved
  59. 59. Take Away Nuggets Prepare for upcoming Changes How will ICD-10 Impact: Therapy coding MDS Coding UB-04 Coding Face Sheets Set implementation timeline Harmony Healthcare International, Inc. 59Copyright © 2014 All Rights Reserved
  60. 60. Pause Medicare Recovery Audit Program February 18, 2014 – CMS is in the procurement process for the next round of Recovery Audit Program contracts. It is important that CMS transition down the current contracts so that the Recovery Auditors can complete all outstanding claim reviews and other processes by the end date of the current contracts. Pause in operations will allow CMS to continue to refine and improve the Medicare Recovery Audit Program. Several years ago, CMS made substantial changes to improve the Medicare Recovery Audit program. Harmony Healthcare International, Inc. 60Copyright © 2014 All Rights Reserved
  61. 61. Pause Medicare Recovery Audit Program February 21st is the last day a Recovery Auditor may send a postpayment Additional Documentation Request (ADR) February 28th is the last day a MAC may send prepayment ADRs for the Recovery Auditor Prepayment Review Demonstration June 1st is the last day a Recovery Auditor may send improper payment files to the MACs for adjustment. CMS will continue to update this Website with more information on the procurement and awards as information is available. Providers should contact RAC@cms.hhs.gov for additional questions. Harmony Healthcare International, Inc. 61Copyright © 2014 All Rights Reserved
  62. 62. Pause Medicare Recovery Audit Program CMS will continue to review and refine the process as necessary. For example, CMS is reviewing the Additional Documentation Request (ADR) limits, timeframes for review and communications between Recovery Auditors and providers. http://www.cms.gov/Research-Statistics-Data- and-Systems/Monitoring-Programs/Medicare- FFS-Compliance-Programs/Recovery-Audit- Program/Recent_Updates.html?siteTool Harmony Healthcare International, Inc. 62Copyright © 2014 All Rights Reserved
  63. 63. Medicare Hearings and Appeals February 12, 2014 Office of Medicare Hearings and Appeals Medicare Appellant Forum Harmony Healthcare International, Inc. 63Copyright © 2014 All Rights Reserved
  64. 64. Medicare Hearings and Appeals Due to the volume of receipts and substantial backlog, implemented deferred ASSIGNMENT process Affects requests for hearing received on and after April of 2013 Requests for hearing held until an ALJ docket can accommodate As of January 24, 2014, estimated delay of up to 28 months until assignment to an ALJ Exceptions: Beneficiary-initiated appeals http://www.hhs.gov/omha/omha_medicare_appellan t_forum_presentations.pdf Harmony Healthcare International, Inc. 64Copyright © 2014 All Rights Reserved
  65. 65. Take Away Nuggets Chart reviews Ensure 1st Level of Additional Documentation Requests (ADR) and Appeals are responded to appropriately Plan for a delay in ALJ. Take detailed notes of case now for review when actually scheduled Keep your guard up. Reviews for now can come later ! Harmony Healthcare International, Inc. 65Copyright © 2014 All Rights Reserved
  66. 66. “It is not the strongest of the species that survives, nor the most intelligent that survives. It is the one that is the most adaptable to change.” Charles Darwin Harmony Healthcare International, Inc. 66Copyright © 2014 All Rights Reserved
  67. 67. Copyright © 2014 All Rights Reserved 67 References Medicare Benefit Policy Manual Chapter 8 - Coverage of Extended Care (SNF) Services Under Hospital Insurance(Rev. 161, 10-26-12) Jimmo v. Sebelius Settlement Agreement Fact Sheet, CMS, April 2013 CMS MDS 3.0 RAI Manual v1.11 September 2013 Harmony Healthcare International, Inc.
  68. 68. Questions/Answers Harmony Healthcare International 1 (800) 530 – 4413 www.Harmony-Healthcare.com KHart@Harmony-Healthcare.com Copyright © 2014 All Rights Reserved Harmony Healthcare International, Inc. 68
  69. 69. Harmony Healthcare International (HHI) For attending this seminar, you are eligible for one of the following: Free PEPPER Analysis Free RUGS Analysis Assess your facility against key indicators and national norms. Contact us at: RUGS@harmony-healthcare.com Analysis is cost & obligation free Harmony Healthcare International, Inc. 69Harmony Healthcare International, Inc.Copyright © 2014 All Rights Reserved

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