Because the Code of Federal Regulations has for many years included skilled restorative as a stand-alone skilled service, I have discussed this at length with the gurus at CMS since virtually all of my clients have been reluctant to stick their toes in the water on this for fear of getting burned.  However, CMS has been very clear that restorative can be a stand-alone skilled service. 

I believe that the addition of the excerpt in the new Benefits Policy Manual helps a lot, but I think there will still be a reluctance to try it until providers are certain that their FIs have gotten the word.  As Tracy's facility found out, not everyone involved knows about this.  The other impediment is that the resident will not RUG into one of the top 26 RUG categories (which isn't a payment problem per se as long as the staff follows the instructions in the RAI User's Manual for Section P3 re: documentation, etc.).  Many providers seem to have the mistaken idea that the lower 18 do not pay well enough to justify the effort.  I urge providers to pull out the rate sheets and compare them to their Medicaid and private pay rates - the RUG payment is almost always much better.

Rena

Rena R. Shephard, MHA, RN, FACDONA, RAC-C
Chair, American Association of Nurse Assessment Coordinators
[EMAIL PROTECTED]


Subj: RE: Restorative as Med A Skilled Need- CITATIONS
Date: 1/19/04 12:33:28 PM Pacific Standard Time
From: [EMAIL PROTECTED]
Reply-to: [EMAIL PROTECTED]
To: [EMAIL PROTECTED]
Sent from the Internet



Theresa, Thanks for the clarification. I agree that if documented well with
nursing intervention that these types of services could be skilled. I think
the problem is with the docuementation being present to show that nursing
was intervening versus only having a restorative nursing flow sheet and no
justification for the skilled purpose of the intervention.

-----Original Message-----
From: Theresa A Lang [mailto:[EMAIL PROTECTED]
Sent: Monday, January 19, 2004 3:24 PM
To: [EMAIL PROTECTED]
Subject: Restorative as Med A Skilled Need- CITATIONS


I will disagree with Christine's response:

Per the Code of Federal Regulations:
"Rehabilitation nursing procedures, including the related teaching and
adaptive aspects of nursing, that are part of active treatment and require
the presence of skilled nursing personnel; e.g., the institution and
supervision of bowel and bladder training programs; * Initial phases of a
regimen involving administration of medical"

Also from the Benefits Policy Manual Chapter 8- Section 30.6

"EXAMPLE A patient who normally requires skilled rehabilitation services on
a daily basis may exhibit extreme fatigue, which results in suspending
therapy sessions for a day or two. Coverage may continue for these days
since discharge in such a case would not be practical. In instances when a
patient requires a skilled restorative nursing program to positively impact
his functional well-being, the expectation is that the program be rendered
at least six days a week. (Note that when a patient's skilled status is
based on a restorative program, medical evidence must exist to justify the
services. In most instances, it is expected that duration of a skilled
restorative program last only a couple of weeks.)."

Per the above 2 citations- I do believe that nursing rehab can be skilled if
correctly documented.

Theresa Lang
Specialized Medical Services, Inc.
Milwaukee WI

-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] Behalf Of
Christine Kroll
Sent: Monday, January 19, 2004 2:07 PM
To: '[EMAIL PROTECTED]'
Subject: RE: Rena: Restorative as Med A Skilled Need?


Restorative nursing programs are not a skilled need by themselves. Nursing
could have skilled for observation and management or careplanning if
documenting the daily skilled services they are providing regarding
assessments and nursing intervention and restorative nursing can be part of
it. Restorative nursing is part of the skilling services in Rehab Low when
in combination with therapy services as legislated; however, by itself
restorative nursing would not be a skilled service.

-----Original Message-----
From: Tracy Adkins [mailto:[EMAIL PROTECTED]
Sent: Monday, January 19, 2004 1:19 PM
To: [EMAIL PROTECTED]
Subject: Rena: Restorative as Med A Skilled Need?


Rena,
I am a MDS consultant in the state of Indiana. CMS is pre-pay reviewing
Medicare A claims in one of my buildings. They call it progressive
correction action plan. They usually request 1 to 2 claims and I prepare
these Medicare A charts and send them in for review. They will either
accect, re-rug or deny each claim. I recently sent in a claim in which the
resident stayed in our facility after all therapy discontinued. Therapy has
set up a restorative program for this resident and we held this resident for

6 days after all therapy had discontinued due to observation of the
restorative program. Administar called the facility last Friday and spoke
with the DON and stated that restorative nursing is not a skilled need. Now,

I'm confused, because I thought it was. Now they want to know where I got
the idea that restorative is a MEdicare A skilled needs and they want the
answer by 5pm today.
Can anyone tell me where I may find in writing that restorative is a skilled

need.
Thank You,
Tracy



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