Avoiding Denials for Therapy Services in SNFs

According to National Government Services (NGS) the most common reason for the denial of Medicare therapy payments is “insufficient documentation.” This finding comes from a task force created by a partnership of all the Part A/Part B Medicare Administrative Contractors (MACs). The data reviewed by the task force came from the Comprehensive Error Rate Testing (CERT) program.

Specifically, NGS states that: “documentation is often missing the required elements as outlined in the Centers for Medicare & Medicaid Services (CMS) Internet Only Manual (IOM) Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Sections 220 and 230.”

Other frequently cited errors resulting in "insufficient" include:

Missing or illegible signature on the plan of care;
Missing or illegible signature for physician's certification; and
Missing legible signature and required treatment minutes in narrative or on flow sheet.

Additional areas that can lead to payment denials covered by the NGS guidance include:

Minimum care planning requirements;
Required signatures and certifications;
Required frequency and content of treatment notes; and
Functional reporting.

NGS offers the following tips to ensure adequate documentation:

Ensure the medical records submitted provide proof the service(s) was certified and rendered.
Ensure the medical records provide justification supporting medical necessity and that skilled services were needed.
Create a complete plan of care, making certain to include your legible signature, professional identification (e.g., PT, OTR/L) and date the plan was established.
Document when the plan of care is modified, including how it has been modified and why the previous goals were not met or could not be met.
Confirm the plan of care is certified (recertified when appropriate) with physician/NPP legible signature and date.
Clearly document, in minutes, the total time spent on timed-code treatment only and the total treatment time (including timed and untimed codes) in the patient's record.

Additional resources can be found on the CMS Therapy Services web page. The complete NGS therapy task force guidance can be found by clicking here.

Contact: Patrick Cucinelli, pcucinelli@leadingageny.org, 518-867-8827