The 2011 Final Rule has introduced a number of new opportunities for homecare agencies to improve their level of service and prove the significant value that homecare brings. One such rule change related to therapy documentation, effective April 1, 2011, could be challenging to manage if the homecare agency has not automated certain processes.
According to these new requirements, a qualified therapist (rather than a therapy assistant) from each discipline caring for a patient must provide services and functionally assess the patient at least every 30 days and prior to the 14th and 20th therapy visit thresholds.
The intent of the Therapy Documentation/Re-assessment provision of the 2011 Final Rule seemed designed to address concerns of therapy use for the small percentage of homecare agencies potentially over utilizing this service. Instead of focusing the solution on only HHA’s with a disproportionate percentage of High Utilization Therapy Episodes all agencies will need to manage to this complicated, challenging requirement.
Of course, with challenge, comes opportunity. We in the industry know that the right mix of therapy services often improves patient outcomes. With data from the new therapy documentation and re-assessment requirements, stakeholders may better quantify the value of homecare and the positive impact which appropriately-utilized therapy cases have to the Medicare benefit, saving thousands in other parts of the healthcare system.
Traditionally, HHA’s have provided therapists much autonomy to perform their professional services. Managing therapy utilization and gathering therapy documentation in a timely manner exacerbates the situation, especially for those homecare agencies utilizing contracted therapy models. For many, it may demand re-working the communications, documentation, and collaboration process between the HHA and contracted therapist if it is not yet effectively automated and optimized.
This leads us to the metric “Time to Information”, or the time it takes for data from an activity (such as a homecare therapy visit) to turn into information. At Sansio, our design philosophy for the HomeSolutions.NET EMR system enables HHA’s to reduce Time to Information in key operational processes. By reducing Time to Information, the person needing specific information to do their job has it available to them in a timely manner, yielding benefits of efficiency, accuracy and improved care coordination.
As part of the Software as a Service model (SaaS), HomeSolutions.NET now includes updated functionality to help HHA’s comply with this regulatory requirement. Our approach to this provision has been to design a Therapy Review page, pre-billing alerts and edits, and scheduling/requirements tracking that validates compliance and helps customers identify and evaluate therapy variance. Additionally, HomeSolutions Mobile has updated PT and OT Evals and Visit Notes to facilitate electronically documenting the re-assessment and progress toward goals. To fully maximize the features and associated benefits of using an automated system such as HomeSolutions.NET, HHA’s should consider their operational processes and decrease their “Time to Information”.
In the case of therapy documentation management, it becomes even more critical for the HHA to receive the therapy documentation immediately after the visit is complete. It will no longer be manageable for the HHA to track down late, or out of sequence, visit documentation. If a therapy note comes in out of sequence, it may still be in compliance with orders/frequencies, but out of compliance with the timing of the re-assessment as currently defined in the new therapy provision.
As a software developer, we can provide information only as quickly as upstream data is available to the system. By using the HomeSolutions Mobile Point of Care option for electronic visit documentation and requiring therapists to submit their visit documentation as soon as the visit is complete, HHA’s will be able to better manage to the provision and eliminate “out of sequence” visit scenarios such as above.
It will also be more critical to reconsider how and who is managing the schedule for therapy visits. With a centralized schedule securely accessible and manageable throughout the organization, all stakeholders can make decisions based on real-time information.
By building a prospective schedule to the orders and following dashboard guidance on managing the dynamic nature of scheduling changes, combined with Mobile Point of Care for real-time therapy electronic visit documentation, HHA’s can maximize the benefits of their automated systems to help manage the new therapy requirements.