Q: Is there a penalty if a SNF resident receives more than 25% of his or her therapy in a concurrent or group setting?
A: There is no penalty at this time, but you will receive a warning edit on the MDS 3.0 NH Final Validation Report that will inform you that the patient has been reported to have exceeded the 25% limit.
The edit will state: “The total number of group and/or concurrent minutes for one or more therapy disciplines exceeds the 25 percent limit on concurrent and group therapy. Consistent violation of this limit may result in your facility being flagged for additional medical review.” CMS also will monitor provision patterns and be aware of facilities that exceed the limit and will revisit the idea of a penalty for exceeding the limit in the future.
The priority in these instances is to review the information for accuracy and then validate that the mode of therapy was appropriate. Concurrent therapy skilled intervention must be clearly documented and connected to at least one individualized goal in the plan of care; group therapy must be justified in the resident’s medical record and include:
• The specific benefits to that person;
• The documented type and amount of group therapy; and
• How the prescribed type and amount of group therapy will meet the patient’s needs and assist the patient in reaching the documented goals.
In some cases, the 25% limit may be surpassed due to circumstances beyond your control. The percentage is calculated based on the resident’s total therapy, and if the resident discharges unexpectedly, for example, group or concurrent minutes may exceed what was initially projected. Again, the emphasis will be on the appropriateness of the treatment provided.
