Demonstrating the Value of Speech-Language Pathology Services in the Patient Driven Groupings Model (PDGM)

Demonstrate Your Value! 

The Patient Driven Groupings Model (PDGM) for Medicare reimbursement was implemented in home health agencies (HHAs) on January 1, 2020. PDGM bases payment for treating patients with speech-language pathology needs on their clinical characteristics. Here are some ways in which speech-language pathologists (SLPs) can demonstrate their value in this payment model.

Identify and Provide Comprehensive Coding of Patient Needs

SLPs play a critical role in identifying patients who would benefit from skilled services for speech, language, voice, swallowing, and/or cognitive disorders. Accurate and comprehensive coding that recognizes all relevant diagnoses and comorbidities/complexities is critical to ensure speech-language pathology services are appropriately reimbursed. In addition, improved coding accuracy provides Medicare with more complete data on the conditions for which SLPs are providing services, which could support advocacy efforts to make positive payment policy changes.

Improve Quality of Care and Compliance

SLPs play a critical role in ensuring quality improvement and avoiding payment adjustments under the value-based purchasing program (VBP), the quality reporting program (QRP), the annual survey and certification process, and Home Health Compare.

For example, HHAs with high readmission rates to hospitals or other negative quality metrics could receive a 2% payment reduction. In addition, HHAs found out of compliance with Medicare survey and certification standards can face civil monetary penalties. Helping your administrator understand the role SLPs can play in compliance and quality improvement reinforces your value beyond the per-visit payment.

In addition to understanding Medicare requirements, SLPs should think about what quality issues might be arising in their HHAs based on their caseload or recent in-service trainings the HHA has provided to its employees. Speaking with your administrator about your role in addressing issues within the individual agency helps ensure SLPs maintain employment and patients receive safe, high-quality care.

Help Complete the Outcome and Assessment Information Set (OASIS)

Engaging SLPs in the completion of relevant sections of the Outcome and Assessment Information Set (OASIS) ensures accuracy of the data, helps identify patients who need speech-language pathology services, and facilitates interprofessional practice. It can also ensure accurate reimbursement to the HHA when patient needs are identified in a timely fashion. SLPs can contribute to this process either directly or in consultation with the HHA staff who complete the OASIS. For example, the patient’s level of functional impairment is one factor for payment. SLPs can help identify patients at risk for hospitalization as a part of this functional assessment.

Serve as a Resource to the Interdisciplinary Care Team to Make Sure They Identify and Meet All Patient Needs

All disciplines must step outside their silos and collaborate more to ensure that patients receive adequate care. Agencies must remember that SLPs can improve/enhance goal achievement in other disciplines through effective communication when a patient presents with communication and/or cognitive deficits.

Avoid Errors in Documentation and Claims Submission

SLPs play a critical role in ensuring documentation supports the claims submitted by the facility. They can help avoid negative audit findings such as:

• Changes in payment that result from changes in the coding or classification of HHA patients versus actual changes in case mix.
• Development of patient-centered plans of care, including frequency and duration of treatments.
• Discharge planning and recommendations to promote safe transitions and minimize risk of re-hospitalization.

Assist in Developing Strategies for Patient Medication Management

Although the medication management clinical category does not include a therapy payment, SLPs effectively develop strategies and tools to ensure that patients can manage their medications safely and accurately. This is particularly important for patients who are not compliant with their medication regimen due to swallowing and/or cognitive disorders.

Maintain Compliance With the Medicare Conditions of Participation

Medicare requires HHAs to have a plan in place to mitigate the decline of patients due to pain, falls, skin integrity, and depression. The SLP can be useful in implementing strategies to assist with pain management (e.g., ability to adequately communicate pain, request pain medications) and fall prevention (e.g., using compensatory strategies and valid tools such as The Spaced Retrieval technique for safety awareness and problem-solving strategies).

ASHA Resources

• ASHA’s Medicare Home Health Resource Center
• Multiskilling in Home Health Care

Questions? Contact ASHA’s health care policy team at reimbursement@asha.org.

CMS Resources

• CMS Resource Center on PDGM