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Is That in My Job Description? 6 Staffing Considerations under PDGM

Late last year Inc. Magazine identified six workforce trends that would impact employers in 2019. The list includes low unemployment, scarcity of job candidates, the influx of younger workers, and the expanding role of artificial intelligence and automation. While all of the above trends certainly affect the home health and hospice market, there is one that the magazine didn’t mention that will have an even bigger effect on post-acute care: Patient-Driven Groupings Model or PDGM.

The new rule from the Centers for Medicare & Medicaid Services (CMS) – a case-mix adjustment methodology – goes into effect in January, changing the way agencies are paid. It moves home healthcare billing from single 60-day episodes to two 30-day episodes and eliminates the impact of therapy volume on payment. When the rule was originally announced in November agencies expressed concern, but as the end of the year draws closer anxiety is taking hold. At first glance, it didn’t seem like something that would affect staffing. It’s about payment, after all, but upon closer examination it’s pretty clear that, for most agency and human resources executives, everything is about to change.

“One of the important things that needs to be done ahead of PDGM is looking at employee retention, engagement, and recruitment especially, I think, on the therapy side,” explains Diane Link, the founder of consulting firm Link Healthcare Advantage. Here at Forcura we’ve made our own list: the top six staffing-related questions that home health agencies must consider in preparation of PDGM.

 

1) Are staffing responsibilities clear and concise?  

Reimbursement will change significantly under PDGM. In the past, patients were categorized into one of 153 groups. As of January 1, patients will be assessed based on five different case-mix variables – admission source, timing, clinical grouping, functional impairment levels, and co-morbidities – creating 432 case-mix groups, which will be used to adjust payment levels. The more seriously ill a patient is, the more an agency will be paid. Skilled nurses may end up spending more time on patient care, which means some tasks such as gathering information for Outcome and Assessment Information Set (OASIS) may need to fall to therapists and other home health care providers. This may not be welcome news.

“There's going to be a lot of changes in the way that therapy is utilized, and discussions need to happen now with our therapists to make sure that they're on board with possibly doing different tasks,” adds Link, who is also a managing partner/COO of Curaport. She points out, for example, that many organizations currently do not require their therapists to gather OASIS documentation.

“Things have to change under PDGM for agencies to be successful,” she adds. “They're definitely going to have to maximize every visit, which leads to the point of not sending a nurse out to do an OASIS assessment when there is a therapist available to do it.” Bottom line: With PDGM having the potential to double the number of episodes an agency deals with each year – and most agencies having to make do with their existing staff – all of your employees may need to learn new skills and accept new responsibilities. It’s up to you to communicate with employees now so they aren’t blindsided by the changes.  

 

2) Do your employees understand what PDGM is?

As a healthcare executive, it’s your job to understand the new regulations and rules coming out of CMS. When it comes to your therapists and nurses, however, they may think their job is taking care of patients and doing any associated paperwork. They may have heard about PDGM, and they know the change is coming, but they don’t realize how it will affect them directly. They should, though.

“Employees need PDGM education,” says Link. “They need to know what the changes are and what they need to do differently in the face of those changes. For example, if you are using a case management model, the case manager needs to understand what their duties are.”

The time to start this education process is now. Build training and education sessions into your workweek so that employees have time to digest and learn – you don’t want them rushing or multitasking. If you’re not comfortable doing it alone, CMS has a wonderful set of tools that you can share with your team including a presentation with audio to go along with it, and there are consultants and online courses available, too.

 

3) Are employees currently using Your EHR correctly?

Your EHR is going to become even more crucial as PDGM is implemented, which is why you need to assess your current staff and make sure that they have a good understanding of the EHR functionality. You’ll also want to make sure that everyone – from care providers to therapists to back office workers – is using it to its fullest potential.

Once you’ve done this, reach out to your EHR vendor and see what plans they have in place to support PDGM. Ask them if they’ll offer training to customers on any new functionality, and get on their training schedule as soon as possible. For instance, if your EHR is adding additional modules to help calculate Low Utilization Payment Adjustment (LUPA) payments, make sure your employees know how to use them. The best technology vendors should also have a product roadmap available to share, says Link.

 

4) Do your therapists, nurses, and back office staffers have the right tools to do their jobs effectively?

When it comes to both the efficiency and documentation that PDGM will require, technology is truly your best friend. It cuts out time spent on paperwork and drives to and from provider locations to get signatures and share documentation. In addition, technology that enables integration – bringing together disparate EHRs and applications – will also help.

Going back to the example of LUPA, employees will no longer be able to calculate LUPA on paper. They will need a tool that does it for them, says Link. “In today’s world LUPA is less than five visits. In the PDGM world, LUPA could be anywhere between two and six visits. You’re going to need an automated way to figure out your LUPA threshold number so that you can manage your visits to meet the needs of the patient but still be fiscally responsible,” she says.

Employees will also need document workflow, care coordination, and communication tools so they can do their jobs in the new compressed timeframes. 

 

5) Do you need to hire anyone?

While many agencies may be able to make do with the employees they already have, some may require more skilled nursing to meet PDGM requirements. Others will need additional back office workers to handle the expanding documentation and filing needs.

If you’re making new hires, consider hiring candidates that have more than just home healthcare experience. The best candidates will have time management skills, excellent communication and organizational skills, and be technologically savvy.

 

6) Can your employees find and educate physicians that are slow or non-compliant with physician signature requirements?

We already hear our customers lamenting the fact that they too-frequently have a hard time getting orders signed in a timely manner. Shortening billing episodes to 30-days requires everything in the workflow to move faster. Agencies should start thinking about –at the very least – the current average time from sent to signed. You need to know now which physicians you struggle with the most, because once PDGM goes into effect it’s only going to get harder to get them to comply. It’s going to be difficult if not impossible to figure out unless you’ve added automation to your current process of tracking outstanding orders.

This list of tasks looks daunting, but partners like Forcura are here to help you and your staff to be PDGM ready with our technology solutions. We understand PDGM's multitude of challenges, particularly when it comes to staffing and efficiency. We’re all in this together, and we will get to the other side.

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Windy3

In her role as Director of Strategic Partnerships and Client Experience, Windy is responsible for the implementation, optimization, and sustained success of Forcura’s clients and partners.  Her expertise is in optimizing organizational processes and the utilization of Forcura’s tools for back-office and clinical success when it comes to the unique challenges that home health and hospice organizations face with regulations.
Connect with Windy on LinkedIn.

Topics: CMS Regulatory Guidance, Maximizing Back-office Efficiency, healthcare

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