Are you Triple Checking???
Background data:
AANAC, in February of 2013, noted in their survey of the tasks occupy the MDS Coordinator on a daily basis, that the triple check process was only being used in approximately 40% of nursing homes. Also, that those facilities that did some form of triple check did not include the MDS or Medicare staff. This is surprising considering the increase in audits from MAC’s, RAC’s etc.
So, what is triple check? It is a distinct review process completed prior to billing to compare the MDS data, to therapy documentation and what has been documented on the UB 04. Basic areas of the UB 04, such as the 3 day qualifying hospital stay, the RUG’s billed and the number of days at each RUG level, if there is more than 1 RUG billed, ancillary billing and ICD coding. Staff ask, why worry about ancillary billing accuracy?? Well, once a bill is submitted, the facility should update that bill with any new charges. Keep in mind that the ancillary charges contribute to your cost reports. Thus, if not correct or not corrected when new data is obtained, your cost reports will not accurately demonstrate the cost of each residents care. When you do triple check, nursing will note any ancillaries, outside therapy and pharmacy, to ensure they were noted on the UB 04. If not, the billing staff should pursue the invoice for the service so as not to have to go back and fix that issue when the invoice is later received.
When should you do triple check??Prior to billing for any residents. Some facilities that do a high Medicare volume, do the process weekly while low medicare users might do the process twice a month or monthly.
Who is involved in triple check process??MDS staff, Medicare nursing staff, billing office staff, coders and the therapy manager.
What does each person bring to the process?? MDS staff and Medicare nursing staff bring the MDS data and ancillary services. Billing office bring the completed UB 04. Coders bring documentation of how the codes for use on the UB 04 were decided. The data is usually found on the hospital discharge summary, the hospital transfer form or a clarification order from the physician upon admission. The therapy manager brings the therapy logs used to complete section O of the MDS. Comparisons are made between MDS coding and the exact therapy logs that are a permanent part of the clinical records.
What do we do with the data we find?? You would want to correct any errors that, regulatory wise, can be corrected such as errors on the UB 04 not related to the MDS. MDS coding or errors that would affect a RUG payment, need an indepth review of the issue and be corrected only in following MDS manual and CMS regulations.
Can this process be viewed as a corporate compliance or a QAPI program?? Definitely. It meets all the criteria. You would want to track trends and plans of correction on an ongoing basis.
If you would like a policy and procedure and forms to complete this process, e mail: