Why Therapy Compliance and Documentation Integrity Must Remain Top Priority

The Importance of Therapy in a Post-RUG World

October 10, 2025

Since October of 2019, the Patient Driven Payment Model, or PDPM, has been the payment system for Medicare Part A in Skilled Nursing Facilities. Prior to this, payment was made under Resource Utilization Groups, or RUGs, which reflected payment based on high therapy or nursing needs.

This shift meant that, where high utilization of therapy minutes once drove the highest reimbursement, PDPM now spreads payment across Case Mix Groups. I often hear, “Therapy isn’t driving the bus anymore.”

While reimbursement is no longer directly tied to therapy time, therapy remains the number one reason for skilled services in a SNF. That means therapy documentation and outcomes are still under the microscope—especially during audits from Medicare Administrative Contractors, or MACs. The rationale for skilled therapy and the documentation standards have not changed.

So, how can you demonstrate the integrity of your therapy documentation and support the exceptional work your therapists provide?

Therapy compliance and documentation integrity must remain top priorities. Here are four key strategies to ensure your Medicare claims get paid and withstand audit scrutiny:

Conduct Regular Audits

- Review a random sample of therapy charts monthly or quarterly.
- Compare skilled intervention notes against CPT codes billed to confirm accuracy.
- Evaluate whether documentation clearly justifies medical necessity and skilled care.

2. Strengthen Documentation Standards

- Ensure skilled intervention language is clear, measurable, and patient-specific.
- Link therapy goals directly to functional outcomes.
- Document progress—or lack thereof—along with clinical reasoning for plan adjustments.

3. Monitor Therapy Compliance KPIs Key performance indicators may include:

- Average Length of Stay for Part A patients.
- CPT accuracy based on skilled notes.
- Total minutes treated vs. planned schedule.
- Accuracy in mode of treatment documentation (individual, concurrent, group).
- Timely and complete orders and certifications.
- Accuracy of Section GG assessments to ensure alignment with therapy documentation.

4. Foster Interdisciplinary Collaboration

- Promote regular communication between therapy, nursing, and administrative teams.
- Share outcome data in care plan meetings.
- Ensure all disciplines tell the same patient story in the medical record.

The shift to PDPM changed how we get paid, but it didn’t change the importance of high-quality, defensible therapy documentation. By focusing on compliance, strengthening documentation standards, and fostering collaboration, you protect both your patients and your facility.

Let’s keep therapy at the heart of skilled care—where it belongs.