A leading MDS 3.0 expert emphasized the importance of substantiating each minute of rehab therapy delivered in a skilled nursing home. According to Leah Klusch, RN, BSN, FACHA, the ability to verify all of the rehab therapy delivered in a facility protects the facility from increasingly common audits and surveys.

Medicare & Medicaid Services is currently focused on Medicare Part A fraud, and rehab claims are being looked at very closely. Several steps can be taken to ensure compliance with MDS 3.0 requirements.

It is recommended that therapists are trained on the rules, timelines and definitions included in the MDS 3.0 manual. The manual contains definitions and directions for coding minutes of therapy to be included on the MDS. If therapists are properly trained, the facility will have confidence that the minutes of therapy are correct and reflect program definitions. In addition to substantiating each minute of rehab services delivered, every skilled nursing facility employee who bills minutes to rehab services must be able to verify that he or she has read all of the updated to the RAI Manual.

The majority of post-payment audit activity is focused on documentation from therapy records. The MDS 3.0 process demands resident-specific plans, documentation, and summaries for rehab services. Thus, rehabilitation documentation must be resident-specific and progress to goals should be stated in terms of skilled service and the resident’s actual progress. Ensure that the documentation is specific to a resident’s diagnosis and situation, and reflects sufficient and accurate information in the event that claims are questioned.