A Roadmap to Medicare Manual Success

By Heidi Rose Bender, MBA

So you’ve decided to become a certified rehabilitation agency and now you need to assemble and maintain a Medicare manual?

This may seem like an overwhelming task at first, and it is, of course, no small undertaking. However, organization is the key. Once you create a roadmap of the steps you need to take to create your manual, the development of each section of the manual becomes a much less intimidating task. In the end, your roadmap will lead you to a manual that is thorough, complete, and will meet Medicare’s rigorous standards.

Where to begin? Medicare, of course. Medicare is the single best source of information about their policies and what they require in a manual. State Operations Manual Appendix E – Guidance to Surveyors: Outpatient Physical Therapy or Speech Pathology Services is a great place to start to develop an outline for your policies and procedures, which will be a foundation of your manual. The state operations manual establishes survey protocols and interpretive guidelines to provide guidance to personnel conducting surveys. This process is of utmost importance because Medicare has already created the roadmap for you! The State Operations Manual Appendix E is a framework of everything Medicare requires in a survey, and by extension, a Medicare manual.

Exactly how does the State Operations Manual Appendix E apply to your clinic’s manual? Let’s delve into one standard and see how it translates to your manual. §485.709(c) Standard: Personnel Policies states: “Personnel practices are supported by appropriate written personnel policies that are kept current. Personnel records include the qualifications of all professional and assistant level personnel, as well as evidence of State licensure if applicable.”

Therefore, your manual should detail all of your personnel policies including:

• Policies and procedures for selecting qualified personnel
• Policies and procedures for documenting verification of the current licensure and/or certification
• A policy describing the system for assessing competency of all personnel providing healthcare services
• A policy describing the frequency of direct supervision for all qualified personnel
• A policy for continuing education requirements;
• A policy for hiring/firing practices
• A policy describing staff evaluations
• Policies and procedures for documentation to be placed in personnel records (e.g., license, certification, competency checklists, adverse actions, annual evaluations, continuing education certificates, etc.)

What is next? Go through each standard in State Operations Manual Appendix E and make sure you have policies that support and meet each one. The current version of the manual is 56 pages in length and covers everything from patient care policies to pest control. It will give you a good idea of what you need to develop a strong Medicare manual.

What if you find that you need a policy but currently do not have one written? You have a few options. You can use a consultant who provides template versions of many Medicare policies which you can purchase for a fee and customize for your clinic. Make sure if you do choose to purchase a canned policy, you take the time to modify it for your clinic. A surveyor will notice if you do not have customized policies applicable to your facility. Or you can write the policies yourself. If you do your research, you can find free templates for many policies. For example, it is easy to perform an online search and find a policy describing staff evaluations. Once again, you need to take the time to customize the policy to your clinic. What are the pros and cons of each option? Chances are a consultant will have a solid idea of the specifics that Medicare is looking for in a policy. However, you will pay for their expertise. On the other hand, if you write the policies yourself, it will likely be a more time-intensive process as you will have to do research to make sure the specifics of your policies are up to Medicare’s standards. General policies such as personnel policies may be fairly straightforward to write on your own. However, you may wish to seek the guidance of a consultant for more complex policies.

Are there any policies that stand out regarding complexity? One policy that has become more complex in the last year or two is emergency preparedness. On November 16, 2016, Medicare established new and significantly more detailed emergency preparedness requirements for Medicare and Medicaid participating providers and suppliers. All surveyors were trained in these requirements via the Integrated Surveyor Training Website (https://surveyortraining.cms.hhs.gov/).

As of November 15, 2017, surveying the new requirements began. This means when a surveyor comes to your clinic, they will review your emergency preparedness policy with a fine-tooth comb. Make sure you are prepared and that your emergency preparedness plan meets the new standards, which include a mandatory all-hazards risk assessment. Watch the training module that all surveyors completed and make sure your plan meets their guidelines.

Electronic or paper? How should you develop your manual—electronic format or paper? There are pros and cons to each option. An electronic manual is easily accessible to all employees. If you have multiple locations, chances are you will have multiple employees working in or accessing your manual for a variety of reasons. Making the manual available on a secure cloud- or server-based platform will enable ease of access for all necessary personnel. In addition, having an electronic manual makes it easy to check if the manual is being updated on an ongoing basis as it should be with in-services, meeting minutes, employee sign-offs, and the like. One caution is that you must make sure you have your manual securely backed up. You do not want someone to inadvertently swipe your manual into the trash on their computer and wipe out all of your hard work. Therefore it is critical to make sure your manual is backed up on an ongoing basis. A paper manual is adequate for stand-alone clinics. There is no risk that it can be electronically swiped into cyberspace. And if you have only one location, it will be easily accessible to all employees. However, after several years, a paper manual can get quite lengthy and take up multiple binders. So depending how large your practice is and how tech savvy, you can make a decision that suits your needs.

Your manual is assembled, so you are done and can breathe a sigh of relief, right? Not so fast. While it is a huge relief to complete your manual, the process of maintaining it and keeping it current has just begun. You need to update and add policies as dictated by Medicare guidelines. Meeting minutes and in-services should be added to your manual on a monthly basis. Separate fire and disaster drills need to be conducted, recorded, and added to the manual at least once per year. CPR tracking must be logged in the manual on an ongoing basis. And these are just a few of the areas that must be tracked, monitored, or updated on a frequent basis. Therefore, I recommend creating a checklist or “cheat sheet” for your manual that specifies all of the sections that require routine updates or monitoring. The checklist will help you stay on the roadmap to Medicare manual success!

Heidi Rose Bender, MBA, is a PPS Administrators’ Network member and vice president of operations for MRS Physical Therapy in Pittsburgh, Pennsylvania. She can be reached at h.bender@mrsphysicaltherapy.com.