Serving the home health, home care and hospice industry since 1999.

by Darcey Trescone, RN, BSN

To date, we know that PDGM will result in significant changes for agencies and the Electronic Medical Record (EMR) software they use. Quality and compliance with regulations, including how care is provided and what is documented, will become even more critical. If you have attended the webinars and read the numerous articles, you understand this. But what does this really mean to you as an agency?

Review Current Internal Processes 

  • If internal processes across your organization are labor intensive now, then anticipate this intensity will likely increase with PDGM, resulting in higher operational costs. In addition, timeliness of care, complete and accurate clinical documentation, and detailed order and claims management will be expected and your time frame for completion of all these areas will be reduced.

  • If internal processes are not in line with the design of your EMR system, then you may not benefit from the changes your EMR vendor makes to accommodate PDGM.

EMR area likely to be impacted:

All EMR vendors have been communicating with customers about PDGM. Many have begun to share their plans for development. It is imperative that your EMR vendor's plans be reviewed alongside your present system utilization and internal processes, looking for operational changes that may be required of you. The change to a 30-day episode will require agencies to deliver, document and bill for care in a condensed time frame.  

  • Referral management – accurate referral source tracking that flows thru to the claim

  • Episode and visit management – visits in line with order and documentation, missed visits with documented course of action, productivity tracking/management, 30-day periods of care including recertifications, identification and tracking of LUPAs, timely documentation of visits

  • Diagnosis coding – accurate diagnosis coding and sequencing will drive CMS behavioral adjustment assumptions (critical this is reviewed/managed while a patient is on-service)

  • Clinical documentation – supports the need for home care, correlates to the diagnosis by body system including complex wound management, care paths based on patient clinical grouping/comorbidity coding, clinical plans demonstrate an effort to improve the patient's status in line with functional levels/limitations and co-morbidities

  • Order management – orders must be written, signed and received back in a timely manner

  • Enhanced Oasis - scrubbers and quality review practices (including tracking and monitoring tools to ensure care compliance)

  • Real time tracking and dashboards – high risk patients including hospitalization risk stratification, visit counts by diagnosis grouping, late episode LUPAs, labor costs: operationally and in the field

  • Billing and claims management - 30-day episodes, timeliness tracking/management of claims, financial reporting and changes to revenue recognition

Put a change management team and process in place now

Change management and education on internal processes and EMR software changes should be planned for and monitored closely.

  • Pay attention to what changes your EMR vendor is planning, including enhancements that are intended to create operational/clinical efficiencies. These efficiencies could help keep your operational costs down and meet clinical care compliance requirements.
  • It will be more critical than ever to attend your vendor's user group meeting this year. This will be their opportunity to explain their PDGM updates in detail.
  • Align your internal processes with the design of your EMR system while documenting those areas that do not align with the design. Areas that the EMR system does not address you will need a plan for.

  • Educate operational and clinical teams on PDGM, EMR vendor plans and changes to your internal processes that will need to occur. This will take time and your team will have feedback. Listen to their feedback and incorporate it into your documented processes and education going forward.

  • Continually monitor operational and clinical teams understanding of PDGM and how your processes will support compliance with PDGM.

Remember that CMS is doing this to fulfill their responsibility to Medicare beneficiaries, not to healthcare providers. Home health agencies will be held accountable to comply with PDGM as the provider of patient care. It is also the agencies' responsibility to ensure the EMR tool they are utilizing supports and manages their PDGM compliance efforts. Clearly, planning for changes you will need to make to adapt to PDGM, internally and with your EMR vendor system, must begin now.


Darcey Trescone is a Healthcare IS and Business Development Consultant in the Post-Acute Healthcare Market with a strong background working with both providers and vendors specific to Home Care and Hospice. She has worked as a home health nurse and held senior operational, product management and business development positions with various post-acute software firms, where her responsibilities included new and existing market penetration, customer retention and oversight of teams across the U.S., Canada and Australia. She can be reached at


©2019 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan's Home Care Technology Report. One copy may be printed for personal use; further reproduction by permission only.