CMS is taking a closer look at “case mix creep” and questioning whether changes in PDPM case mix reflect true patient acuity or shifts in documentation and coding practices. As potential reimbursement changes and increased scrutiny loom, accurate, consistent documentation is more important than ever.

Click below to read the full article to understand what CMS is watching and what SNFs should be doing now. 

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Question:  Are facilities required to issue two notices related to bed holds? 

Answer: Yes, before transfer or therapeutic leave, the facility must provide the resident or their representative with written information that includes the duration of the state's bed-hold policy, if any, during which the resident is permitted to return and resume residence in the facility; the reserve bed payment policy in the state plan, if any; and the facility's policies regarding bed-hold periods and permitting a resident to return.

At the time of transfer for hospitalization or therapeutic leave the facility must provide the resident and the resident representative with written notice which specifies the duration of the bed-hold policy. There is often confusion as to whether the second notice must be given at the time of transfer or if it can be provided in person or via mail at a later date. This second notice must be provided to the resident and/or their representative at the time of transfer or for an emergency transfer, within 24 hours. The facility must document multiple attempts to reach the resident’s representative in cases where the facility was unable to notify the representative at the time of transfer.

Responses reflect general regulatory guidance and may vary by state, payor, or circumstance.

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