HP Enterprise Services Summary Report of LTC Facilities Reviewed July 2013 Tracking Number E20130222 Prepared August 2013 HP Restricted 1 Contents July Contents Overall Summary for Long Term Care Health Services Introduction – Long Term Care Unit ..................................................................................................................... 4 Volume ............................................................................................................................................................ 4 Quality ............................................................................................................................................................. 5 Validation rate and Reconsiderations ....................................................................................................... 5 Training ........................................................................................................................................................... 5 Audit variations – July 2013 ............................................................................................................................ 6 Introduction ..................................................................................................................................................... 6 Findings .......................................................................................................................................................... 6 Analysis by Risk Category ........................................................................................................................ 7 Areas of Concern ...................................................................................................................................... 8 Statistics by RUG Classification...................................................................................................................... 9 Level of Care Statistics ................................................................................................................................. 10 PASRR Level II Statistics.............................................................................................................................. 10 Recommendations ........................................................................................................................................ 11 HP Restricted 2 July 2013 Health Services Overall Summary for Long Term Care The Long Term Care (LTC) Unit completed sixteen Minimum Data Set (MDS) audits during the month of July 2013. The mean validation rate for the providers audited during the month was 89.44%. The threshold during an audit is currently 80%. The LTC Unit received one requests for reconsideration of audit findings in July. The validation rate and minimal requests for reconsideration indicate that LTC continues to be successful in helping providers achieve compliance with Indiana Health Coverage Programs (IHCP) rules and regulations. The purpose of the LTC review is to ensure that the IHCP is reimbursing for the appropriate RUG classification as demonstrated by the MDS version 3.0 and supporting documentation. Changes to the MDS audit frequency were implemented January 1, 2010. The LTC auditing team also performs Level of Care (LOC) and Pre-Admission Screening Resident Reviews (PASRRs) of LTC residents. The following risk criteria are used in selecting nursing facilities for audit: Audit every nursing facility (NF) at a minimum of once every three years based on the following criteria: Low-risk provider ○ Previous audit score of 90 – 100% – audit at a maximum of every three years Medium-risk provider ○ Previous audit score of 80 – 89.9% – audit at a maximum of every two years High-risk provider ○ Previous audit score of 79.9% or lower – audit every four to 12 months The Office of Medicaid Policy & Planning (OMPP) reserves the right to perform additional MDS audits as deemed necessary at any time. The objectives of the HP LTC audits are as follows: Determine whether residents continue to have needs requiring NF placement in accordance with State LOC criteria defined by 405 IAC 1-3-1 and 405 IAC 1-3-2. Ensure all services recommended by the Level II assessments are provided. Verify that the MDS responses that impact the RUG score are accurate and supported with the appropriate documentation within the assessment reference period. Determine whether IHCP is reimbursing the provider for the appropriate RUG-III classification, reflective of resident needs. NFs may be notified up to 72 hours prior to the scheduled case mix/LOC/PASRR audit. The LTC auditing team conducts an entrance and exit conference to apprise the facility staff of the nature, purpose, and sequence of events of the audit, as well as the audit results. The auditing teams are available throughout the audit to address facility questions and concerns. These (The) auditing teams consist of qualified professionals, including registered nurses and licensed social workers. These team members may be qualified mental retardation professionals (QMRP) or designees. The facility is responsible for ensuring that all resident medical records are complete, up-to-date, and available to the auditing teams. Facility staff will also need to assist the LTC auditing team with resident observations. Documentation in each resident’s medical record must support all notations made on the MDS form. HP Restricted 3 July 2013 Health Services Health Services Introduction – Long Term Care Unit The LTC Unit performs retrospective service provision and case-mix auditing functions. The LTC staff members conduct on-site audits of Medicaid-certified LTC facilities. Oversight is provided for the Division of Aging (DA) and the Office of Medicaid Policy and Planning (OMPP). In addition the LTC staff members assist providers in achieving compliance in documentation and billing, as well as helping ensure the health and safety of the Indiana Health Coverage Programs (IHCP) members. Volume Figure 1 illustrates the number of audits completed by month. For the period of August 2012 through July 2013, HP completed 179 audits. HP Restricted 4 July 2013 Health Services Quality Validation rate and Reconsiderations The LTC Unit has a respected presence in the provider community, as evidenced by the relatively small number of requests for reconsideration (refer to Table 1) and overall validation performance (refer to Table 2). Less than 2% of audits resulted in facilities requesting reconsideration of audit findings. Following each case mix audit, nursing facilities receive final results electronically with instructions for how to request informal reconsiderations for reviewed records that failed to support. Facilities may request reconsideration of audit findings for specific records within 15 business days of receiving their initial findings from HP. The reconsideration request must include specific audit issues that the facility believes were misinterpreted or misapplied during the audit. It should be noted that MDS supporting documentation that is provided after the audit exit conference shall not be considered in the reconsideration process. Table 1 Reconsideration requests Reconsiderations Number Received July 2013 # of Initial Audit Findings Upheld 1 1 Table 2 Monthly validation rate statistics Validation Threshold, per IAC 80% Audit Timeframe Average Monthly Validation Rate August 2012–July 2013 88.4% Training LTC auditors discuss with providers audit decisions and provide education throughout the audit process. Providers have shown appreciation for these discussions. The LTC Unit plans to continue to conduct Supportive Documentation Guidelines (SDG) training via virtual room throughout 2013 and encourage LTC providers to reference the IHCP website for future training information. HP Restricted 5 July 2013 Health Services Audit variations – July 2013 Introduction The Audit Variations report provides information on nursing facilities (NFs) that demonstrate a variation between their previous case-mix audit validation rate and the current validation rate. NFs that exceed the 20% error threshold rate as outlined in the Indiana Administrative Code (IAC) receive a 15% Administrative Component Corrective Remedy penalty applied for one quarter. The Nursing Facility is required to respond to a Validation and Improvement Plan (VIP). All unsupported worksheets are reclassified, and the NF is subject to a Case Mix audit within 12 months. Findings The LTC unit completed sixteen Case Mix audits in July 2013. The Case Mix audit validation rate average was 89.44%. The variation by gain or/loss percentage was 32% to -29%. One new NF validated at 100%. Eight NF’s reflected a decrease in the validation rate from the previous audit, ranging from -1 to 29 percentage points. One NF had no change at 96%. Six NF’s validated higher than the previous audit. The validation ranged between 32 and 3 percentage points higher than the previous audit. During July, two Case Mix audits were expanded; one provider’s validation rate at the conclusion of the audit exceeded the threshold. The expanded portion of the audit resulted in an additional 8 hours of audit time. The team educated each facility about 450B & Level I requirements, as well as reviewed the SDG’s regarding Activities of Daily Living (ADL’s), active diagnosis, impaired cognition and nursing restorative elements. HP Restricted 6 July 2013 Health Services Analysis by Risk Category Three Low Risk providers stayed Low Risk. Four Low Risk providers became Medium Risk. One Low Risk provider became High Risk. Two Medium Risk providers became Low Risk. Four Medium Risk providers stayed Medium Risk. One High Risk provider became Low Risk. One New provider became Low Risk. HP Restricted 7 July 2013 Health Services Areas of Concern Ten Areas of Concern were statistically relevant upon analyzing data for the month of July 2013. These elements had 20% or greater inconsistency with the MDS data transmitted by the NF, when at least 10 or more records were reviewed this month. Table 3 Areas of Concern on the MDS 3.0 found during audits completed in July 2013. Percent of Element Unsupported Inconsis tent Records # NF’s 75% 9 5 7 5 C1000 62% 29 8 14 6 O0500B 55% 6 4 5 4 C0700 54% 14 7 9 4 O0500F 53% 8 4 1 1 I2000 47% 9 5 2 1 O0500G 44% 15 9 8 4 I4900 38% 5 4 4 3 O0500H EATING/SWALLOWING 38% 6 4 0 0 M1200A PRESSURE REDUCING - CHAIR 34% 24 12 0 0 O0700 RUGs # Not NF’s Supp Element Description DECISION MAKING AROM SHORT TERM MEMORY PROBLEM WALKING PNEUMONIA DRESSING/GROOMING HEMIPLEGIA/HEMIPARESIS PHYSICIAN ORDERS oNursing Restorative, Diagnoses and Impaired Cognition have remained the top Areas of Concern. HP Restricted 8 July 2013 Health Services Statistics by RUG Classification This table summarizes monthly statistics for all facilities reviewed, including number of records reviewed and the percentage of records fully supported. Resource Utilization Groupings (RUG) further breaks down the statistics. TOTAL 8/12 EXTENSIVE SERVICES 888 112 91 95 105 28 66 86 66 56 96 32 55 FULLY SUPPORTED 770 92 81 86 94 26 56 74 58 51 86 20 46 87% 82% 89% 91% 90% 93% 85% 86% 88% SPECIAL REHABILITATION 2,633 398 263 272 297 123 203 223 163 154 216 109 212 FULLY SUPPORTED 2,528 381 249 260 292 119 196 215 156 150 204 105 201 96% 96% 95% 96% 98% 97% 97% 96% 96% SPECIAL CARE 811 101 96 97 69 35 67 75 61 68 63 37 42 FULLY SUPPORTED 654 73 78 87 61 29 51 55 52 55 49 27 37 81% 72% 81% 90% 88% 83% 76% 73% 85% CLINICALLY COMPLEX 1,578 192 139 129 124 73 139 160 154 131 149 81 107 FULLY SUPPORTED 1,367 158 115 111 109 67 128 142 130 117 131 66 93 87% 82% 83% 86% 88% 92% 92% 89% 84% IMPAIRED COGNITION 422 76 21 37 15 25 40 30 35 45 48 28 22 FULLY SUPPORTED 325 54 16 32 13 25 31 17 30 32 41 20 14 77% 71% 76% 87% 87% 96% 78% 57% 86% BEHAVIOR 18 4 2 2 0 1 0 0 2 1 4 1 1 FULLY SUPPORTED 10 1 1 1 0 0 0 0 2 0 4 1 0 56% 25% 50% 50% 0% 0% 0% 0% 100% 100% 0% REDUCED PHYSICAL 910 113 111 78 47 17 104 42 106 118 72 31 71 FULLY SUPPORTED 746 95 96 56 36 15 80 28 98 88 61 30 63 82% 84% 87% 72% 77% 88% 77% 67% 92% RUG Category % % % % % % % 9/12 10/12 11/12 12/12 HP Restricted 1/13 2/13 3/13 0% 100% 4/13 5/13 91% 90% 97% 94% 81% 78% 89% 88% 71% 85% 75% 85% 6/13 7/13 94% 84% 96% 95% 73% 88% 81% 87% 71% 64% 97% 89% 9 July 2013 Health Services Level of Care Statistics The Level of Care Statistics reports data for nursing facilities audited during the month. The number of IHCP members, whose charts were reviewed is delineated into the following categories: total audited, those having a Medicaid number, those not having a Medicaid number, those no longer in the NF, discharge recommendations and those with Mental Illness (MI) or intellectual disability (ID) or those dually diagnosed (MI/ID/DD) recommended for discharge. All residents present at the time of the audit were observed in the course of the on-site audit. TOTAL FACILITIES Total MA REVIEWED Audited Residents Others 16 510 298 Res No Longer in NF 57 MI/ID/DD No LOC Recommend D/C Ref DMHA 136 0 0 PASRR Level II Statistics The PASRR/Level II Statistics reports information for nursing facilities reviewed onsite during the reporting month. Incorporated into the Case Mix audit is a PASRR component for current residents, whose charts are reviewed, that includes review of Level I and review of the Level II, as applicable. The audit team requests documentation from the nursing facility identifying residents that have a PASRR Level II due to MI/ID/DD. The audit team compares the list provided by the nursing facility with the actual PASRR Level II documents for verification of current status. Audit teams review the medical chart for compliance with Level II recommendations for at least five residents with a Level II confirming MI, ID or MI/ID/DD. The LTC audit teams also note if documentation on the active medical record indicates the need for a Level II, and when one has never been completed, the audit teams will make referrals. TOTAL FACILITIES REVIEWED 16 Referrals for new Level II’s MI Residents 13 ID Residents 120 18 MI/ID/DD Residents 10 In nine of the sixteen NF’s audited this month, thirteen residents were referred for Level II’s for the following reasons: ○ Two residents were referred for potential Intellectual Disability; One resident had a diagnosis of Cerebral Palsy admitted one month ago from home without a Level II; the other resident had diagnoses of Depression and Cerebral Palsy without a Level II; with ongoing psychotropic medication administration and receiving psychiatric services. ○ Four residents had diagnoses of Depression, with medication administration two also had signs and symptoms of Depression. ○ One resident had a diagnosis of Depression; with medication administration and receiving psychiatric services. ○ One resident had diagnoses of Depression, Anxiety and Bi-Polar Disorder; with medication administration and signs and symptoms. ○ One resident had diagnoses of Schizophrenia and Depression with medication administration. ○ One resident had a diagnosis of Schizophrenia; with medication administration and receiving psychiatric services. ○ Two residents had a diagnosis of Psychosis with medication administration, only one was receiving psychiatric services. ○ One resident had no diagnosis; with suicidal ideations noted and medication administration. HP Restricted 10 July 2013 Health Services Recommendations 1. The HP LTC unit will continue to emphasize the following requirements during provider audits and training: ○ Utilization of The Center for Medicare and Medicaid Services (CMS) Resident Assessment Instrument (RAI) manual for Active Diagnosis; that RUGgable diagnosis has two parts, physician signature within 70 days and “Active” meaning documentation within the 7 day time frame of the direct relationship of the diagnosis to the resident’s current status. ○ MDS 3.0 requires individualized, measureable care plans for nursing restorative and evaluations completed in the 7 day assessment time frame. ○ Impaired Cognition elements (not BIMS) still require documentation of examples. 2. Encourage NFs to review the MDS 3.0 updates on the CMS website. 3. Encourage NFs to view the Long Term Care page of indianamedicaid.com, where the LTC team plans to continue Virtual Room training on the Supportive Documentation Guidelines. 4. Continue to update the Long Term Care page of indianamedicaid.com with relevant topics and links including the Monthly Reports. HP Restricted 11