CGS Ohio Comprehensive Error Rate Testing Highlights

Arbor Rehab was pleased to be able to attend the CGS CERT Roadshow presented in Cleveland on June 26, 2024. Although the errors discussed were not surprising, the frequency of these errors was. Medicare FFS improper payment estimate is at 07.38% or $31.23 Billion dollars! Missing or insufficient documentation accounts for 4.91% of these errors nationwide. For the SNF sector, the lack of documentation did not support the level of care reported, did not support the billing codes used and /or certifications / re-certifications were incomplete.

It would seem correcting these errors may be easier said than done. Although the requirements for Medicare compliance are straight forward, everyone on the team needs to be on-board and diligent with their documentation. At Arbor Rehabilitation, our therapy teams are routinely audited and educated on existing standards and updated regulations. Strong documentation of medical necessity and skilled interventions within a reasonable time frame are our hallmarks. This goes a long way and supports our high success rate with any therapy related ADRs. We also work with facility staff to maximize their supportive documentation with Sections C, J, K and GG on the MDS. In turn, facilities realize higher outcomes, quality ratings and regulatory compliance with less Targeted Probe and Educate involvement.

Unfortunately, no one can solve a problem that goes unrecognized. This is true for the need to address any ADRs that may come across a nursing facility's desk. The CGS CERT Roadshow highlighted that in several cases, ADRs were not responded to and no information was submitted, resulting in a denial of payment. This can happen if letters from CGS are misplaced or left unopened in a timely manor. Presenters at the Roadshow strongly urged facilities to check the My CGS portal to ensure all ADRs are accounted for and addressed. Additional recommendations include a signature log for facilities with manual signatures, double checking that all orders are in place - signed and dated appropriately, certifications are signed and all documentation is complete.

Although this is not rocket science, in the busy days of facility staff, these errors happen with surprising frequency. Stable and well educated teams are a strong ally in avoiding cumbersome audits and reviews. Effective partnerships are key in this era of scrutiny!