The therapy team plays a pivotal role in ensuring quality compliance and promoting person-centered care within nursing facilities.
In November 2024, the Office of Inspector General (OIG) released its Nursing Facility Industry Segment-Specific Compliance Program Guide to assist facilities in identifying potential risks and establishing effective compliance monitoring strategies.
This document, updated annually, emphasizes the need for customized compliance plans tailored to the specific needs of each facility, taking into account its unique characteristics and operational structure.
The OIG highlights four key risk areas in its 2024 report:
- Quality of Care and Quality of Life
- Medicare and Medicaid Billing Requirements
- Federal Anti-Kickback Statute
- Other Risk Areas
Therapists’ Role in Quality Care and Compliance
Based on the 2024 compliance program guidance, consider the following areas to ensure alignment with OIG recommendations:
- Quality of Care and Quality of Life: Development of Care Plans and Resident Activities
Question: Is there a failure to develop and implement comprehensive care plans by the Interdisciplinary Team (IDT)?
Recommendation: The OIG stresses the importance of collaborative care planning that accurately reflects the resident’s needs and goals, including the input of the therapy team.
- Medicare and Medicaid Billing Compliance
Documentation of Services: The OIG emphasizes the necessity of proper documentation for all services rendered, including therapy services. This documentation must accurately reflect the care provided and its alignment with the resident’s treatment plan.
Internal Reviews and Audits: The OIG recommends that nursing facilities conduct periodic internal reviews to assess the adequacy of therapy services and ensure that care delivery meets the specific needs of residents. These audits help prevent underutilization of services.
- Value-Based Payment Models
Compliance Program Structure: The OIG advocates for robust compliance programs that include auditing, monitoring, and training initiatives. Data monitoring is particularly essential in assessing performance under value-based payment models, which focus on outcomes rather than service volume.
Key Considerations for Therapy Compliance Monitoring
To assess your therapy team’s alignment with the OIG’s recommendations, consider the following questions:
- Does the therapy team collaborate with other disciplines when creating care plans, or are therapy goals developed independently?
- Is discharge planning effectively communicated to both family members and the interdisciplinary care team?
- Are residents’ needs, preferences, and therapists’ recommendations fully integrated into care planning?
- Are care plan meetings and decisions adequately documented for compliance purposes?
- Does therapy documentation support skilled care and clearly reflect the involvement of qualified clinicians?
- Is there a standardized, cookie-cutter approach to therapy treatment, or is care customized to each resident’s unique diagnosis and needs?
- What measurable quality outcomes are being achieved through the therapy team’s interventions?
The Importance of Person-Centered Care
True person-centered care is realized when all team members, including therapists, work together to prioritize residents’ needs, preferences, and safety.
By aligning with the OIG’s guidance, your facility can ensure that therapy services not only comply with regulatory standards but also enhance the overall well-being of residents. Regular reviews, audits, and a collaborative approach to care planning are essential for maintaining compliance and fostering high-quality outcomes for those in your care.
Blue & Co. offers a team of highly knowledgeable consultants dedicated to supporting your Post-Acute Care needs. Whether you require assistance with Therapy Operations, Clinical Reviews, Payroll-Based Journal (PBJ) reporting, 5-Star ratings, regulatory surveys, Value-Based Purchasing (VBP), or MDS support, our experts are here to help. Please contact a member of our Post-Acute Care team below or reach out to your local Blue & Co. advisor for personalized guidance.
Landon Hackett, CPA, MSA, Director
Liz Barlow, RN, CRRN, RAC-CT, DNS-CT, QCP, Senior Consultant
Stephanie Fitzgerald RN, RAC-CTA, CPC, Manager
Kayla May, CPA, Manager
Missy Deeg, CPA, Manager
