Time is Ticking--Here's Tom's PDGM To-Do List


Over the past six months we have all been introduced to PDGM. Sure, you’re tired of hearing about it--but what are you doing about it?

The industry as a whole is trying to teach everyone the pros and cons, but the real question you need to ask your yourself is: Do you have a concrete plan developed and underway specific to your agency? What adjustments can you make today to benefit you tomorrow--or in this case, Jan 1, 2020? If you’re like most agencies, you need help.

To get you started, I’ve put together this PDGM to-do list.

  1. Review and understand the clinical and financial impact of PDGM to your agency. This will take some time but diving deep into the data is essential. You can’t create a solid strategy without understanding what areas of your business are going to be affected most.

  2. Educate your clinicians. How well do your clinicians understand the clinical documentation of co-morbid ICD-10 codes? This is a good place to start your evaluation.

  3. Examine the 12 clinical groups (See table below) and how your patient mix will be affected. Specifically:

  4. What are the current visit ratios?

  5. What is the Average Length of Stay (ALOS) for the patients in those 12 clinical groups?

  6. Audit the impact to your intake team. Ensuring documentation, like the complete medical record and assessment, is appropriately gathered and documented will be essential. This includes history and physicals, discharge planning documents and consolidated clinical document architecture (CCDA) documentation if possible. Getting these attached to the medical record and then available to the evaluation clinician will make it easier to document a more complete medical picture of the patient.

  7. Review the effect on your billing and financial team. There will definitely be more “churn” or workflow steps to keep up with in the PDGM paradigm. Is the billing team proficient in its processes and staffed correctly to ensure timeliness of billing?

  8. Work closely with the clinical staff to ensure they understand the importance of timely documentation. Clinical latency in completing and reviewing start of care (SOC), recerts and orders will impact reimbursement.

  9. Book a reserve to ensure the business can cover any delays in payment processing. Don’t forget the Fiscal Intermediaries (FI) have to make major adjustments to ensure they are ready to change their business practices. Historically, delays have happened.

  10. Consider your orders management processes. How do you get your orders written, signed and processed? This system needs to be timely and compliant, so billing can manage it quickly. Where necessary, add systems and portals. Additionally, educate referral sources on the changing needs so they can work with you in gaining efficiency. Start now!

  11. Prioritize clinical documentation reviews. Most agencies have a lag in the clinical documentation review process. A full assessment of the clinical pathways, physical assessments and interventions and goals should be reviewed to prepare for the PDGM changes. Although, this task is daunting and time consuming, completing the effort will ensure you are accurately documenting your patients’ disease processes while also ensuring your coders are accurately coding the patients’ co-morbidities.

  12. Assess and review therapy programs. Sure, patients still need therapy and we will continue to provide it, but what is the process to ensure the therapy and nursing evaluations get completed to ensure one quality plan of care is determined? Again, timeliness is so important to this process. Don’t forget to re-teach your teams on the impact of the new Low Utilization Payment Adjustment (LUPA) rules. These will definitely have an impact to your business.

  13. Train for OASIS. Ensure clinicians understand the questions and appropriate answers as well as how to work with the review team to ensure feedback and corrections. This will reduce errors and rejections.

  14. Test and report the validity of the ongoing impact. It’s important to identify challenges and react quickly. You will have delays in payments and process failures. It’s how quickly you identify them and address them that matters.

These are just a few of the items we are addressing with our clients today. Keep in mind, while these are all valuable areas in general to focus on to improve efficiencies for PDGM, the most valuable recommendations are personalized.

We’re happy to work with you through an agency-specific PDGM assessment. If you like what you see, we can move forward with our hands-on PDGM optimization. That includes us coming on site to implement your agency-specific PDGM plan. You can view the one pager on our PDGM service here.

As I write this article, I continue to think back to all the other times impending doom surrounded us. PDGM does not have to be that bad. Get prepared now! Create a project plan, start tackling the appropriate items, don’t procrastinate and remember--we can survive this change just like we did Y2K, six versions of OASIS, PCRD, Face-to-Face and many other changes. Plus, what would we worry about around the holidays if it’s not CMS changes to our processes?

MHA is here to help you reach your highest level of efficiency. Our consultants are prepared and ready to assist you in driving these changes, training your staff and supporting your efforts. If we can be of assistance, don’t hesitate to reach out to info@maxwellhca.com. Please take care of each other. --Tom


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