Navigating the COVID-19 public health emergency can be difficult for skilled nursing facilities (SNFs). However, no matter what the challenges are—staffing shortages, time-consuming infection prevention and control practices, the need to rearrange schedules and duties to preserve personal protective equipment (PPE), residents who need extra time and attention, or the myriad other issues—providers still have to be paid, and that means nurse assessment coordinators (NACs) need to do internal audits so they are ready to back up Patient-Driven Payment Model (PDPM) case-mix classifications for Part A residents if a Medicare auditor comes knocking.
What to do going forward
“The key to efficient PDPM internal audits during a COVID-19 outbreak or any crisis is focus,” says Robin Hillier, CPA, STNA, LNHA, RAC-MT, president of RLH Consulting in Westerville, OH. “Obviously, the best practice is to audit every MDS item and look for missed coding opportunities, as well as double-checking what you have already coded. However, that may not always be a realistic option, especially during a pandemic when, for example, you may need to work the floor because of a staffing shortage. In addition, a full audit isn’t necessary to be sure you can defend your billing to a Medicare auditor.”