The administrative burden placed on Behavioral Health agencies that accept Medicaid or commercial insurance payments is substantial. You are being asked to document everything, and it can seem overwhelming and cumbersome. But the penalties for missing your Treatment Planning requirements are real, and they’re harsh.
First, consider how a Medicaid audit works. Medicaid comes to audit a select number of your charts. If they discover that 1 out of the 10 charts in their sample had services performed without a valid treatment plan in place, there is no further investigation to discover how many actual services were performed with a treatment plan. Instead, they will apply a 10 percent penalty across all of your services during that time period.
Even if the 1 delinquent chart was the only one that you have, your agency would have to payback 10% across the board for services you provided, unless you can prove otherwise. Every state has regulatory compliance guidelines when it comes to treatment plans and treatment plan reviews, so it is imperative that you stay on top of your treatment plan management.
Here are my 5 keys to successful treatment plan management:
- Know what your regulatory timelines are
While technology can help you, you need to know what your regulatory deadlines are when it comes to treatment planning management. Deadlines can vary by state and service modality, and it is important that you know the timelines that govern your treatment plans (within each service modality) so that you can set your technology accordingly. Whatever warning/alerting system you have for treatment planning due dates needs to account for more than just the due date. See number 5 below.
- Don’t provide services without valid treatment plans
If you see appointments coming up for clients that don’t have valid treatment plans in place you should reschedule them or if time allows, complete the treatment plan or review prior to the upcoming appointment. Providing the service without prior completion of the treatment plan/review will leave your agency in the position where billing for the service will put you at a serious audit risk. The idea here is to ensure you have an awareness on what services you have scheduled where you do not have valid treatment plans in place. The best practice is to ensure you have treatment plans up to date, but in the event that you don’t, rescheduling the appointment is the safe bet.
- Write-Off any visits that are performed without a valid treatment plan
As tempting as it may be to bill out for a service that was provided without a valid treatment plan in place, don’t do it. The revenue gained from a single service is not worth the risk of the payback you may have to pay as the result of negative findings from an audit. If you have service providers conducting visits without a proper treatment plan in place, you need to write-off those charges instead.
- Run Regular Reports
Running the right reports or having a means to forecast what treatment plans are coming due (or overdue for that matter) will help you stay on top of your regulatory requirements in respect to treatment planning and ensures that you don’t provide services that you can’t bill for. I recommend viewing the treatment plan forecast for treatment plans/reviews that are overdue and due in the next 10 days on a regular basis.
Overdue treatment plans require immediate action, and plans that are due in the next 10 days provides you a chance to take action that will keep you ahead of having to delay appointments or provide services for free.
- Know your business process
It is so important that you know how your agency operates. You have to understand all of the components required to ‘complete’ a treatment plan/review, and know how your agency functions to make all of those happen. For example, if your treatment plans have a medical component and your medical provider is only in the office once a week, planning around that schedule can be the difference between compliance and going a week without a valid treatment plan. In short, it is imperative to consider all aspects that factor in the completion of a treatment plan/review.
Treatment plan management isn’t a financial issue at face value, but mismanagement can lead to serious financial implications to your agency. Use these 5 keys as a starting point for managing your treatment plans, and remember to report against your number of overdue treatment plans so that you can make positive impacts to your business process that will help you stay in a positive state of compliance.