Others in my facility still do not agree with therapy 5x/week interrupting a wellness period.... actually they are not really agreeing with anything except MCR A usage interrupting a benefit period....  They do agree a tube feeder never becomes "unskilled" for a 60 day wellness period, but I am having a hard time with Stage IV ulcers, therapy 5x/week with 150 minutes, etc. being reasons the resident has been skilled... I am just learning this myself... we were just looking to see if MCR A had been used in the past 60 days.   If any of you have time (I know how valuable time is for all of us), please read the response below that I received from out therapy company & let me know what you think.   I really need help with this.
Here is the response:
 
Hey Jamie,

I have continued to research the question you have about interruption of
wellness period with Med B therapy 5 times per week.  I agree that it is
technically correct to say that therapy 5 times per week constitutes skilled
service, and it seems logical that this could interrupt a wellness period.
However,  I have not been able to find a single episode where provision of
therapy under Med B, actually interfered with Med A coverage within 60
days.  I have also searched the CMS website and found nothing which
specifically addresses the interruption of wellness period due to provision
of Med B therapy 5 times per week.  That doesn't mean its not an issue, just
that it is not addressed that specifically.  I have however been able to
find a couple of incidents at ------------, where a patient
received Med B therapy 5 times per week, went out to the hospital and came
back in, all within a 60 day period and received Med A 100 days without
question.  Again, that doesn't mean it won't ever be an issue, but to this
point it hasn't been.  I also came across several questionnaires that
different facilities use to determine Medicare A eligibility, and not a
single one ask the question if therapy had been provided 5 times per week in
a SNF setting in the prior 60 days.  Again, doesn't mean its not an issue,
but I haven't found any facilities that are taking Med B therapy provision
into account when determining Med A eligibility.

Also in regards to the definition of skilled care, there is the statement
about "the patient whose inpatient stay is based solely on the need for
skilled rehab services would meet the daily basis requirement if they
receive those services at least five days a week," and of course our Med B
patients are not receiving inpatient care solely based on rehab need.

I think you are being very proactive to avoid a potential problem which is
why you are so good at what you do! I'm glad I've learned how knowledgeable
you are with this stuff so I can use you as a resource.  I just don't want
to be quick to react to a potential problem, since we have no historical
precedent or any documentation where CMS addresses the issue specifically. 
At least no documentation that I've been able to find.

I believe that we should proceed as follows:

1.  I can emphasize the need for individualizing Med B frequency with the
therapists.  Frequency decision should be based on clinical need and not
everyone needs to automatically receive 5 times per week.  By that same
token, I wouldn't want to see all Med Bs suddenly go to 3 times per wk. This
lower frequency would not be clinically appropriate for many of our
swallowing, positioning or splint patients.

2.  Let me know if there is a specific patient that you feel is at
particular risk for hospitalization and need for wellness period.  If a
hospital admission and need for Med A benefit is highly probable, then we
can jointly determine if its in the best interest of that patient and the
facility to treat 3 times per week instead of 5, or even 4 times per week.

3.  Most importantly, I will have the therapists do whatever my customer
says!   If the powers that be decide that we should aggressively move towards
seeing our Med B patients 3 times per week, we will comply.

4.  Finally, I will continue to search for more concrete answers and you do
the same.  I'm going to try to reach ________ today.  She has always been
a good resource for me.

Keep me informed of anything you find out and I'll do the same.  Thanks,

_________________________________________________________________
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locations.
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----- Original Message -----
Sent: Tuesday, February 24, 2004 8:37 AM
Subject: wellness period

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