Functional Pathways - Rehab the Right Way

Clinical Compliance

Therapy and Nursing Home providers are coming under increased scrutiny from regulators and consumers. Compliance with all applicable laws and regulations must be a key component of any Quality Improvement process. Functional Pathways is committed to continuing to monitor potential target areas of noncompliance through ongoing quality improvement processes that address both specific concerns at the facility level, as well as company identified trends and trends identified by regulators as areas of concern to ensure continued compliance with all applicable laws and regulations.  Functional Pathways’ approach to quality and compliance through partnership with the facility is a proactive approach that ensures the highest practicable level of quality care to the residents served by both Functional Pathways and their customers.

Functional Pathways’ approach to compliance is to partner with the client to ensure that all therapy programs are in compliance and address the following components through focused resident audit reviews that are strategically selected from medical records to represent records which could be a trigger for additional document request from Medicare auditors related to patterns of RUG utilization and length of stay:

  1. Evidence that documentation supports the medical necessity of the therapy services provided
  2. Evidence that provided therapy services are supported by treatment logs and progress notes
  3. Evidence that documentation supports that the therapy services provided are skilled in nature
  4. Whether documentation includes the diagnosis for which the treatment was provided, the resident’s prior level of function, and the date of onset for the diagnosis for which treatment was provided
  5. Whether documentation includes restorative potential, short and long term goals, types of services/modalities provided, documentation or expectation for progress, change in condition, and ongoing progress
  6. Evidence of signed and dated therapy plans of treatment
  7. Evidence that therapy minutes are documented and support the minutes billed
  8. Evidence that the therapy documentation supports the RUG classifications.

Functional Pathways commitment to partnering with the client to assure a Quality Improvement approach towards maintenance of compliance with provision of therapy services includes participation in the following activities:

  1. Utilization Review processes including participation in Triple Check Audit processes
  2. Review of MDS and nursing documentation to validate that there is support of therapy services provided
  3. Participation in facility Quality Improvement meetings
  4. Educational sessions and webinars for the purpose of developing and reviewing action plans for identified trends in compliance as well as to be proactive in preventing issues from occurring.

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