Under PDPM, the SLP Component is underutilized. Proper coding and training can enhance care and reimbursement in skilled nursing facilities.
Under the PDPM in skilled nursing facilities, the SLP Component is often significantly underutilized. Reviews show substantial variation in reimbursement per resident per day between facilities that accurately capture and code the SLP Component and those that do not. The variance in the SA to SL Case Mix Group is approximately $91.35 per day, which can amount to around $2741 for a 30-day stay. This variance proves a considerable opportunity to take a closer look at the pieces of the SLP Component, the delivery of SLP related services and the associated potential for increased reimbursement.
The SLP Component is composed of the following 5 indicators: Acute Neurological Condition, Cognitive Impairment, ST Comorbidities, Swallowing Disorder and Mechanically altered diet texture.
What are some “Missing Pieces” a facility may consider?
Investing in the Speech Therapy and Rehab Team
- Ensure that your Speech Therapists are present in your facility for sufficient hours and days to deliver exceptional care to residents. This allows timely and comprehensive assessments and treatment, enabling strong clinical outcomes, interdisciplinary focus, and identification of dysphagia and various ST Comorbidities during the ARD lookback period. When ST staff are not regularly scheduled in the facility, there is an increased risk of cognitive, communicative, and swallowing impairments not being treated effectively, and conditions not being identified prior to the ARD, thus not included on the MDS. This may result in missed reimbursement opportunities under the PDPM system.
- Provide the ST staff with regular education related to PDPM, ICD-10 coding, and skilled documentation to ensure they have a strong understanding and use of accurate and compliant documentation that demonstrates medical necessity and supports ST-related coding on the MDS. Investing in adequate training of the rehab team will foster a culture of compliance and understanding of the importance of strong documentation skills, resulting in a reduced risk of claim denials, audits, or penalties for your facility. Empower the ST staff to develop strong relationships with the MDS Coordinator and Physician team, ensuring timely communication and diagnosis queries for SLP-related comorbidities, so these diagnoses are included on the MDS.
Acute Neurological Condition
- Having a process where the interdisciplinary team reviews the resident’s primary diagnosis ensures that the most appropriate diagnosis is selected. Invite the rehabilitation team’s input into this conversation. Often the diagnosis responsible for the resident’s hospital admission is not always the primary reason for the skilled stay. By not considering all active diagnoses, the potential for missing a primary acute neurological condition code may occur, which may impact the overall ST Component Score.
Cognitive Impairment
- Not having a timely or accurate assessment of the resident’s cognition via a BIMS can impact not only the resident’s planned care by the team but also the reimbursement for the facility. Ensure your facility has a strong process in place for conducting BIMS according to RAI guidance. Ensure the assessment is completed and documented prior to the ARD. Consider training the ST/OT staff to properly conduct the BIMS to support the facility team in completing and documenting of this cognitive screening.
ST Comorbidities
- To appropriately capture SLP Comorbidities, it is important to provide the Speech Therapy staff with training and tools related to the approved list of SLP Comorbidities. It is also essential to have a consistent process in place to ensure good communication between the Speech Therapist, Physician, and MDSC, to allow diagnosis queries and supportive documentation of these comorbidities ahead of the ARD, so that they can be appropriately coded on the MDS.
Dysphagia
- Unclear, vague, or missing documentation can result in denials and may provide inadequate information for interdisciplinary team delivery of care or to capture a resident’s swallowing disorder on the MDS. Do your Speech Therapists use “parallel language” to MDS Section K when writing a dysphagia plan of care or progress note? If they are not clearly documenting resident-specific information related to the various aspects of the resident’s oropharyngeal dysphagia, the resident’s swallowing impairment may not be realized for care planning or reimbursement.
Regularly Scheduled Documentation Reviews & Training
- Do not assume all your therapy staff are expert coders, understand PDPM reimbursement, or have essential documentation skills. Schedule regular documentation and PDPM reviews to ensure compliance, identify missed opportunities, and determine areas for necessary training and process development.
Not having all of these ‘pieces in place’ may impact your facility’s compliance and reimbursement optimization. Polaris has the tools and expertise to partner with your team to help.
