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Ignoring ADRs pretty much guarantees more review, expert warns.<\/em><\/strong><\/span><\/p>\n The consequences for not performing well under Targeted Probe & Educate review can be harsh \u2014 and eventually fatal to your agency. Follow this expert advice to avoid getting caught up in a deadly TPE cycle.<\/p>\n 1. Start with the basics: Respond.<\/span>\u00a0<\/strong>HHH Medicare Administrative Contractor\u00a0CGS\u00a0<\/strong>has reported that two of the 15 home health agencies that completed TPE review in the first six months of the program did not respond to Additional Development Requests.<\/p>\n \u201cRespond timely to the probe,\u201d urges\u00a0Joe Osentoski\u00a0<\/strong>with\u00a0QIRT\u00a0<\/strong>in Troy, Michigan. The TPE burden can be heavy, with each round requiring responses to 20 to 40 ADR requests. But \u201cit is really inexcusable these days for providers to not even respond to the ADR requests,\u201d Osentoski says. \u201cNonresponse to a record request virtually guarantees further probes and review.\u201d<\/p>\n 2. Avoid outdated F2F procedures.<\/span>\u00a0<\/strong>Many home health agencies may be caught in an old face-to-face physician encounter rut, where they use a form only, believes consultant\u00a0J\u2019non Griffin<\/strong>, owner of\u00a0Home Health Solutions\u00a0<\/strong>in Carbon Hill, Alabama. Instead, F2F information must be included on the Plan of Care and the agency must acquire the physician\u2019s visit note.<\/p>\n 3. Tighten up F2F review process.<\/span>\u00a0<\/strong>Don\u2019t let F2F requirements slip through the cracks. Create \u201ca face-to-face gatekeeper who knows all the requirements for timing, signature, content, and certification,\u201d Osentoski recommends. That person should review \u201c100 percent of new admissions at time of admission,\u201d he says.<\/p>\n 4. Use your F2F time.<\/span>\u00a0<\/strong>Don\u2019t give up if the F2F requirements aren\u2019t fulfilled at first. \u201cUnderstand that if the face-to-face requirements are not all present [at admission], that agencies can use that 30-day window after admission to get a valid encounter in the record,\u201d Osentoski advises.<\/p>\n 5. Empower your supervisors on therapy.\u00a0<\/strong><\/span>Lack of medical necessity documentation for therapy is a common problem found by MACs in TPE, and one that Griffin sees often. HHA administrators, who are most often nurses, have been hesitant to challenge therapists when they say patients need more therapy, she says. That\u2019s because the nurse administrators aren\u2019t on sure footing with their understanding of therapy requirements.<\/p>\n Do this:\u00a0<\/strong><\/span>Educate \u201csupervising staff on what is considered reasonable and necessary, so they can oversee the documentation also,\u201d Griffin counsels.<\/p>\n 6. Get familiar with therapy LCD.<\/span>\u00a0<\/strong>You can learn the ins and outs of therapy coverage and documentation requirements in Local Coverage Determinations from your HHH MAC. \u201cReview and follow all applicable therapy LCDs,\u201d Osentoski exhorts. \u201cThis is the best defense against therapy documentation denials.\u201d<\/p>\n 7. Pore over recerts with a critical eye.<\/span>\u00a0<\/strong>Claims for recertified episodes are particularly vulnerable to denials. \u201cInitiate a robust recertification evaluation process,\u201d Osentoski urges. \u201cThis applies to therapy reassessments, identifying a current status and a valid reason to continue service into a following episode. There must be specific reasons to continue care: a change in condition, a new treatment, an unplanned event in the prior episode that limited home health achieving its goals.<\/p>\n Red flag:\u00a0<\/strong><\/span>\u201cNever recertify to monitor a condition,\u201d Osentoski emphasizes.<\/p>\n Source- SuperCoder<\/span><\/i><\/a><\/p>\n","protected":false},"excerpt":{"rendered":"