Problems with documentation in skilled nursing facilities (SNF) often lead to claim denials that can negatively impact cash flow and make these facilities susceptible to audits. According to findings in the 2017 Comprehensive Error Rate Testing report, one of the most common errors in medical reviews is missing or insufficient physician certification and/or recertification statements.
To ensure your documentation aligns with the care you have provided your patients, your facility must make the effort to provide all the information necessary for these statements to be considered complete and valid.
What constitutes a valid certification and recertification statement?
While there is no requirement from the CMS for facilities to use a specific procedure or form, documentation must show that a patient required skilled nursing care or skilled rehab services on a daily basis for a condition that was treated or arose during the qualifying hospital stay. This information may be included in a physician’s order or progress notes. Any format is acceptable as long as it verifies the need for initial and extended skill nursing services.
Initial certification must be obtained at the time of admission to the skilled nursing or rehab facility, ideally within 48 hours. If this isn’t possible, it should be signed within a reasonable timeframe. While capturing the physician or non-physician practitioner’s signature is important, confirming that the certification is dated is just as essential. A non-dated certification is not considered acceptable.
The first recertification must be completed, signed, and dated by the doctor or non-physician practitioner no later than day 14 of post-hospital SNF care. This statement must give reasons for the continued need for SNF care, the estimated time a patient will need to stay in the SNF, any plans for home care, and an indication of whether or not the continued need for services is due to a condition that arose after their admission to the SNF.
Subsequent recertifications are required to be signed and dated by the doctor or non-physician practitioner at intervals not exceeding 30 days after the first recertification.
In the event a certification or recertification isn’t signed and dated within a reasonable timeframe, CMS will accept and honor delayed certifications. However, the facility must provide a reasonable explanation for the postponement of completion.
Ensure your facility’s documentation is complete
Reviewing your claims before submitting them to Medicare can help you eliminate costly billing errors. Many facilities implement a triple-check system, a formal process involving team members from multiple departments including billing, clinical, rehabilitation, and administrative staff. Each person on the team is tasked with verifying and crosschecking key data so errors can be identified and corrected before the claims are sent for reimbursement.
To obtain an objective review or to verify internal audit findings, third parties like Excelas are used to complete the triple-check audit.
If you’d like to learn more about Excelas’ triple-check and medical records auditing services, contact us today.