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If you are using Low rehab RUG and have an order
for RNP, in the state of Pa. you can not count the Dr. order for RNP as the
state does not require an order for RNP.
To simplify matters, obtain the
eval order on admission. After the eval, develop a proposed treatment
plan for the physician to approve via a telephone order. That process
meets the Medicare Part A requirement that the therapy treatment plan be
established by the physician after consultation with the therapist.
The following is from the PPS Final Rule (July 30, 1999), p.
41660:
<<QUOTE
The Medicare policy regarding the
requirement for the
physician signature on the therapy plan
of
treatment has not changed. As is
stated in the SNF Manual,
rehabilitation
therapy services provided to a
beneficiary in a SNF
must be directly
and specifically related to an active
written
treatment plan established by
the physician after any
needed
consultation with a qualified therapist.
Implementation of the
PPS did nothing
to alter this guideline. We will,
however, take this
opportunity to clarify
what is required for coverage of
rehabilitation
therapy.
As stated in the language in the SNF
Manual cited in the
preceding
paragraph, Medicare requires the
physician to make decisions
regarding
the amount and intensity of
rehabilitation therapy services
provided
to Medicare beneficiaries in SNFs after
consulting with the
professional
We expect that the same care will be
taken by the
physician and SNF staff to
document physician responsibility
for
developing the therapy plan of
treatment, including precautions,
that is
reasonably expected to be taken for any
other element of the
medical record. We
realize, however, that in the SNF setting
there may
not be a physician on the
premises every day. Therefore,
Medicare
allows the professional therapist to
develop a suggested plan
of treatment
and to begin providing services based
on that plan prior
to obtaining the
physician's signature on the plan. We
continue to
require that the plan of
treatment must be a
physician's
responsibility after any needed
consultation with a
qualified therapist,
and that the requirement for
physician
verification of the suggested plan of
treatment will be
obtained within a
reasonable amount of time. However, a
physician
signature must be obtained
before the facility bills Medicare
for
payment for the rehabilitation therapy
services provided to the
beneficiary
based on the plan of treatment he or she
has approved. In
this way, the facility
can be sure that the level of therapy for
which
it bills Medicare is the level the
physician deems to be
medically
necessary. We expect that the type and
intensity of therapy
billed will always
match the type and intensity of therapy
on the
signed therapy plan of treatment.
>>END QUOTE
In this
process, the telephone order constitutes the treatment plan that the
physician must sign (as long as the orders contain the required
components). The treatment plan ordered by the physician constitutes a
change in the resident's treatment and would be coded on the MDS as a day
with an order change.
Rena
Rena R. Shephard, MHA, RN, FACDONA,
RAC-C
Chair, American Association of Nurse Assessment
Coordinators
[EMAIL PROTECTED]
Subj: RE: Doctors orders
Date: 2/17/04 4:02:05 PM
Pacific Standard Time
From: [EMAIL PROTECTED]
Reply-to:
[EMAIL PROTECTED]
To: [EMAIL PROTECTED]
Sent from the
Internet
No I would call the Dr and ask for a
clarification and THAT I couldn't
count.
I understand the
reasoning behind PPS and the rehab mins. But as you said
most Drs
will not give exact orders unless therapy has evaled them and
you
need an order for that.
-----Original
Message-----
From: Nathan [mailto:[EMAIL PROTECTED]
Sent:
Tuesday, February 17, 2004 5:43 PM
To: [EMAIL PROTECTED]
Subject: Re:
Doctors orders
Where in that order does it give any
indication how much treatment to
deliver? If the Dr. wrote "Give
some antibiotics", would you?
PPS pays based on the amount
of therapy ordered and delivered in minutes and
day. If they paid on
therapy "Yes" or "No" then the Eval and Treat
order
might be ok, but they don't.
----- Original Message
-----
From: "Richardson, Christine"
<[EMAIL PROTECTED]>
To:
<[EMAIL PROTECTED]>
Sent: Tuesday, February 17, 2004 1:49
PM
Subject: RE: Doctors orders
>When a res is admitted
with orders on admission its my understanding these
>can not be
counted unless there is a change in the original orders
during
>that day. Most of my admissions come with evale and treat
orders for
>therapies. The following orders are clarifying the
admission order.
>01/01/04 Admitted with ST/PT/OT orders for evale
and treat( why is this
not
>a complete
order?)
>01/02/2004 received clarification from Dr for
TX
>
>
>
>-----Original
Message-----
>From: Nathan
[mailto:[EMAIL PROTECTED]
>Sent: Tuesday, February 17, 2004
3:35 PM
>To: [EMAIL PROTECTED]
>Subject: Re: Doctors
orders
>
>
>The term "Standard Admission
Orders" does not mean the orders written when
a
>resident
is admitted. This refers to standing orders that are applied
to
all
>admssions for a certain MD. As for not being able to
use admitting orders
to
>count for therapy...I have never
heard. There is a problem when the MD
>writes "Eval and
Treat". That is not a complete order. The MD must as
some
>point indicate the days and minutes of therapy to be
delivered. Therapy
must
>be doctor ordered, not therapist
ordered. If the MD is not willing to
write
>actual minutes and
day without an eval (most won't and I don't blame them)
>This
becomes a three part process to do correctly.
>
>One - MD
writes an order for "Evaluation and recommendation" for
the
>therapist.
>Two - The therapist does the eval and
recommneds X days and X minutes per
>day.
>Three - The MD
then writes a second order for X days and X minutes per day
>of
therapy. I would guess that part three could be fulfilled by an
order
>from the MD to "Eval and Treat as recommended" as
long as the third part
was
>dated/timed after the second part.
In effect, the recommendation of the
>therapist would become part
of the MD
order.
>
>
>Nathan
>
>
>-----
Original Message -----
>From: "Richardson, Christine"
<[EMAIL PROTECTED]>
>To:
<[EMAIL PROTECTED]>
>Sent: Tuesday, February 17, 2004 1:02
PM
>Subject: RE: Doctors orders
>
>
>>Section
P page 3-205 in RAI under physician orders states
>> Does
note include standard admission orders, return admission
orders,
>>renewal orders or clarifying orders with out
changes.
>>
>>-----Original
Message-----
>>From: Jennifer
[mailto:[EMAIL PROTECTED]
>>Sent: Tuesday, February 17, 2004
1:39 PM
>>To: [EMAIL PROTECTED]
>>Subject: RE: Doctors
orders
>>
>>
>>Where does it state we can't
count therapy orders? I
>>read through the whole
section?
>>
>>Jennifer RN BSN MDS
Coordinator
>>
>>--- "Richardson,
Christine"
>><[EMAIL PROTECTED]>
wrote:
>>>Cant count clarification orders, or
therapy
>>>orders.Read section P in
RAI
>>>manual
>>>
>>>-----Original
Message-----
>>>From: [EMAIL PROTECTED]
[mailto:[EMAIL PROTECTED]
>>>Sent: Monday, February 16, 2004
4:47 PM
>>>To: [EMAIL PROTECTED]
>>>Subject:
Doctors orders
>>>
>>>
>>>If a
resident is admitted with orders for Speech,
>>>Occupational
and Physical
>>>therapies that state treat and eval as
indicated,
>>>can you count orders the
>>>next
day when they come in and the order is writtent
>>>to
clarify specifically
>>>what they are going to do for
example: speech
>>>therapy to treat 5x week
x
>>>6weeks for
.......
>>>
>>>Thanks,
>>>Carol
>>>
>>>
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