Assuring Patient Safety and Quality Care in Rendering Respiratory Therapy Services in Nursing Homes

ISSUE:

The implementation of a Prospective Payment System (PPS) for Medicare Pt. A Skilled Nursing Facility (SNFs) has created a new environment for the provision and reimbursement of health care services to Medicare beneficiaries.

Nursing home providers have the responsibility to determine how the clinical needs of the patient will be met and which health care provider will be responsible in rendering the care. Because PPS will result in an overall reduction in SNF reimbursement, nursing homes will have a powerful financial incentive to utilize caregivers who are not qualified, by virtue of their education and competency, to provide respiratory therapy services. This situation will adversely affect both the quality of respiratory therapy services and the health outcomes of the Medicare beneficiary.

SITUATION:

Since November 1997, the AARC has been in discussions with HCFA to revise pertinent Medicare nursing home documents (Resident Assessment Instrument Manual and the Survey and Certification Manual) as it pertains to the provision of respiratory therapy services. The AARC and HCFA have been unable to come to an agreement to include the following critical statement in the aforementioned documents:

"Respiratory therapy services may be provided by respiratory therapists or other health-care professionals who have been trained, educated, and have demonstrated competency in respiratory therapy services through a valid competency examination."

Respiratory therapy is a life sustaining therapy. Therefore, respiratory therapy services rendered by individuals who have not documented their competency in respiratory therapy presents a very real danger to patients. Respiratory therapy rendered by individuals who do not have to document their competency can result in numerous negative clinical outcomes, such as:
(1) providing services that may be inappropriate for the patient's condition,
(2) providing unnecessary respiratory therapy services,
(3) causing an increase in hospital readmissions due to pulmonary complications,
(4) creating longer and more costly lengths of stay,
(5) increasing morbidity, and
(6) causing patient deaths.

SOLUTION:

To require all persons providing respiratory therapy services to Medicare SNF beneficiaries document their competency.

Require the following language be included in both the Medicare Survey and Certification Manual as well as the Resident Assessment Instrument Manual:

"Respiratory therapy services may be performed by respiratory therapists or other health care professionals who have been trained, educated, and have demonstrated competency in respiratory therapy services through a valid competency examination."

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