Inpatient Psychiatric Post-Payment Reviews with On-Site Visit
At least once every three (3) years, Permedion conducts a post-payment review with on-site visit to every Medicaid fee-for-service inpatient psychiatric hospital. The purpose of the on-site visit is to:
- Review the findings in the report sent to the hospital following the post-payment reviews.
- Discuss chart documentation as related to OAC regulation and a best practices standard of care.
- Provide education and make recommendations.
Active planning and preparation will successfully aid a hospital in responding to both the medical records request and on-site visit notification. The following information will support provider efforts.
Medical Record Preparation
- Respond as quickly as possible to medical record requests. Records received after the deadline will result in technical denials.
- Permedion requires the entire medical record. By working closely with the hospital medical records department, ensure that the charts sent to Permedion are complete. If electronic medical records (EMRs) are provided, this is particularly important because Permedion has noted a pattern of important elements missing from these types of charts. The following represents documentation frequently missing from the EMRs received for post-payment review:
- Multi-Disciplinary Treatment Plans with signature pages.
- Contraindications to seclusion and restraint.
- Documentation related to seclusion and restraint.
- Discharge plans with signatures.
- Psychosocial assessments.
- Certificates of Need.
On-Site Visit Preparation
- During the on-site visit, clinical services are discussed at length. Therefore, the hospital’s clinical staff should be well represented. It is strongly recommended that representatives from psychiatry, social work, and nursing be present, in addition to staff from utilization review and administration.
- Prior to the meeting, provide the identified attendees with a copy of the Permedion Findings report. This will allow opportunity for attendees to review the report in preparation for discussion with Permedion representatives.
- Determine and prepare a conference room. Ensure there are enough chairs and space for everyone’s comfort. Ensure privacy and lack of distractions.
- Let the attendees know that although a Permedion on-site visit typically lasts about one (1) hour, it can potentially run longer and so they may want to plan their schedules accordingly
- Explain to attendees the importance of the purpose of the on-site visit.
- Provide Permedion with detailed instructions regarding the location of the hospital and parking. Arrange for a representative to meet the Permedion representatives in the hospital lobby and accompany them to the conference room.
Process for Post-Payment Review with On-Site Visit
It is advantageous for providers to understand the process related to post-payment reviews with on-site visit.
- Permedion mails a medical records request letter to the provider.
- The provider sends the medical records to Permedion within 30 days of the date printed on the request letter.
- The medical records are reviewed by a team consisting of a physician, nurse and social worker. Determinations are made within thirty (30) days of the original medical record submission due date.
- A findings report is sent to the provider.
- When a post-payment medical record review results in a denial, a letter indicating such is mailed to both the provider and patient. The provider denial letter includes appeal instructions.
- The Permedion clinical lead contacts the hospital in order to establish the on-site visit date and time.
- The clinical lead and social worker visit the hospital as scheduled
Protected Health Information
Post-payment reviews require that the entire medical record be sent to Permedion. However, personal health information (PHI) is protected by law in order to support patient privacy. Permedion and providers should work together to ensure that unnecessary records not be shared.
A central aspect of the privacy rule is the principle of “minimum necessary use” and disclosure. A covered entity must make reasonable efforts to use, disclose, and request only the minimum amount of PHI needed to accomplish the intended purpose. A covered entity must develop and implement policies and procedures to reasonably limit uses and disclosures to the minimum necessary. When the minimum necessary standard applies, a covered entity may not use, disclose or request the entire medical record unless it can be specifically justified.
Change of Contact
As needed, hospitals should contact Permedion with any primary contact changes. Permedion’s experience has been that sometimes the proper hospital personnel do not receive correspondence on a timely basis because it was delivered to the incorrect person.
In order to update a hospital primary contact with Permedion, complete the Change of Contact form.