Failure to Submit Timely PASRR NFSS Authorization for Therapy Services
Penalty
Summary
The facility failed to coordinate assessments and submit a complete and accurate request for Nursing Facility Specialized Services (NFSS) in the LTC online portal within 20 days after the Interdisciplinary Team (IDT) meeting for a resident identified as PASRR-positive. The resident, a female with diagnoses including cerebral palsy, non-Alzheimer's dementia, hemiplegia, hemiparesis, traumatic brain injury, anxiety, and depression, was determined to meet criteria for intellectual/developmental disability (IDD) following a PASRR Level 1 screening and subsequent evaluation. The Local Authority Compliance Confirmation indicated the need for PASRR services, including participation in IDT meetings, habilitation services, and monitoring for possible community transition. Despite the resident receiving occupational therapy (OT) and being scheduled for speech therapy (ST), the facility did not submit the required NFSS form within the mandated 20-day period following the IDT meeting. Interviews with facility staff, including the DON, MDS Coordinator, and DOR, revealed that the NFSS forms were left in draft status and never officially submitted, resulting in no authorization for payment for the therapy services provided. The staff indicated that the failure to submit the NFSS was due to a misunderstanding regarding the resident's refusal of services and the continuation of existing therapies, as well as a lack of clarity about staff responsibilities for form submission. The facility's PASRR policy did not reference the 20-day deadline for NFSS submission, and the staff involved at the time of the deficiency were no longer employed at the facility. Documentation confirmed that the resident continued to receive therapy services during the period in question, but the required authorization process was not completed in accordance with state regulations. The deficiency was identified through record review and staff interviews, which confirmed the lapse in compliance with PASRR and NFSS requirements.