CMS has vehemently stated that providers are responsible for producing the same functional outcomes under PDPM as they did under the RUG payment model. Keeping that in mind, there is certainly opportunity to shift traditional restorative program structure while maintaining optimal functional and quality outcomes to avoid financial audits and quality payment penalties – an emphasis on an interdisciplinary team approach to functional improvement is key!

We all know the amount of therapy delivered is no longer the reimbursement driver, however, producing optimal outcomes is! Here are some focus areas you may want to consider when reviewing your current rehab program:

1. A therapist’s established plan of care should be individualized with treatment recommendations based on each resident’s unique needs, goals and potential.
2. The therapy plan of care should include both an explanation and plan that goal achievement will be addressed through the use of group/concurrent therapy and that the resident is appropriate to participate in these modalities.
3. The Interdisciplinary Team (IDT) should be involved in goal achievement (i.e., nursing education that supports discharge goals, etc.).
4. Consider developing or redesigning your Restorative Nursing programs – they can be effective and complementary to supplement traditional restorative services.
5. Establish a process for assessing function and usual performance for coding section GG – it must be a team effort! Relying on PT/OT evaluations on admission to determine your GG score might be driving down your function scores and your reimbursement.

We recognize these challenging times and are here to help you and your team facilitate positive change. If you’d like assistance, please reach out so we can make arrangements for a brief call to see how we can assist you.

Amy Lee, RN, MSN, CRRN, QCP
President/CEO