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Documenting dysphagia services for greater
appeal success
May 19, 2015Adult DysphagiaDocumentation, Dysphagia, MedicareDysphagia Cafe
Documenting dysphagia services for greater appeal success
By: Anna Eakins, MS, CCC-SLP/Appeals Specialist
Photo credit: Jed Sullivan / Foter / CC BY-NC
Solid clinical documentation has long been a focus for many providers. However, since the
launch of the Manual Medical Review in October of 2012, this focus has grown tremendously.
The instance of denials for therapy services has grown exponentially and our single greatest
weapon in recouping payment for skilled and dedicated services remains strong clinical
The Centers for Medicare and Medicaid Services (CMS) and the Medicare Administrative
Contractors (MACs) regulate the documentation policies that oversee Medicare benefits for
rehabilitation. CMS provides a “minimum” guideline for therapy documentation policies in the
Medicare Benefit Policy Manual Chapter 15, Section 220 Coverage of Outpatient Rehabilitation
Therapy Services. An individual MAC may require more specific guidelines under their Local
Coverage Determination (LCD). LCDs can be found on the CMS website.
Denials and appeals ultimately relate back to the broad umbrella of medical necessity; whether a
service lacks complexity, a prior level of function, or objective measures. The following areas of
documentation consistently appear as reasons for denials in dysphagia claims.
Prior Level of Function
Dysphagia claims are often denied due to lack of an objective and measurable prior level of
function (PLOF) (Wisconsin Physicians Services Corporation, 2015). Medical record reviewers
want to see justification for the onset of services. The PLOF provides reference for the current
level of function; thus establishing a change in function and a rationalization for services. At a
minimum, the PLOF should be specific to swallowing and refer to solid textures and liquid
viscosities safely tolerated prior to the change in function. At best, other relative information
regarding the patient’s swallow function, level of independence, cognitive function related to
swallow, weight changes or history of aspiration or other respiratory complications should all be
mentioned as it relates to the patient. In all, the PLOF should be relevant to the plan of care and
to the patient’s needs and goals, and it should always be objective and measurable.
The prior level of function provides a relevant framework to the evaluation findings and
goals. At times, writing the PLOF after writing long-term goals makes this task less daunting. It
also allows for a one to one correspondence between goals and prior levels for improved
structure of the overall plan.
Resident consumed mechanical soft/thin liquids in restorative dining room with minimum cues
for cyclic ingestion at 3:1 solid: liquid ratio. No s/s aspiration or oral residue. No intentional
weight loss x 8 months.
If the PLOF is not available at evaluation, justify proceeding with dysphagia treatment without
having established a change in the patient’s function, and obtain the prior levels as soon as
possible. Document the prior levels upon receipt, tying them back to the plan of care with
adjustments as needed to provide the most appropriate and medically necessary plan of care to
the patient. If the PLOF information is unobtainable, document why and demonstrate the clinical
rationalization for proceeding with treatment without that case history component. At times it is
justified, just be sure to communicate why.
Lack of Baseline Measures with Goals
Goals should have baselines at onset. Baseline measures determine the viability of goals and
establish means of tracking future progress (American Speech-Language Hearing Association,
2011). Without this information, defense of denials for services including initial dates of services
become cumbersome.
Once baseline measurements are established, the same type of measurement must be used
throughout. Whether using percentages, a given number of trials, a level of cues, or a
combination of these types, consistency is non-negotiable.
Goals Not Targeting Impairments
Whether intending to compensate or remediate, short-term goals should always target the
impairments impacting swallow function. This establishes the skill and complexity of dysphagia
services at the onset. To that effect, goals for exercises should be avoided. Exercises are tools for
achieving goals related to impairment and function, but the completion of exercises is not a goal
itself. (Centers for Medicare & Medicaid Services, 2014).
Patient will perform cyclic ingestion at a solid: liquid ratio of 2:1 with moderate verbal cues on
9/10 trials for decreased oral residue and aspiration/choking risk.
Patient will increase labial seal for no-minimal left anterior loss of p.o. intake given minimal
verbal and tactile cues on 4/5 trials for increased intake, dignity, and quality of life.
Further, well-written goals, both short and long-term, are patient-centered, functional and
Demonstration of Skill in the Progress Note
Demonstration of skill and medical necessity of services is of the utmost importance to a
Medicare reviewer. Documentation must support that not just anyone can provide the
services being billed. The progress note serves as the go-to document for demonstration of skill
and medical necessity (Centers for Medicare & Medicaid Services, 2014).
Demonstrate skill first through objective measures of progress in the plan of care. Remember to
remain consistent for easy tracking. At times, patients suffer acute illness and exhibit no progress
or even regress. If so, document the cause and the plan for treatment modification to facilitate the
patient’s function moving forward (Centers for Medicare & Medicaid Services, 2014).
Further, interventions used to attain this progress should also be documented. Avoid broad
descriptions such as “compensatory strategies” or “dysphagia training” and use specifics such as
“effortful swallow,” or “chin tuck” and discuss the specific purpose of the intervention.
Avoid the rut of documenting the number of coughs at meals with no physiological explanation
or clinical plan as this appears more like rote observation than skilled intervention. When
documenting signs and symptoms of aspiration or dysphagia with trials, include descriptions of
the impairment while addressing plans for remediation. See below for an example:
Patient showed signs of aspiration with trials of NTL on 4/10 trials with moderate verbal cues to
“swallow hard”. Presents with moderately impaired tongue based retraction, impairing bolus
propulsion posteriorly for effective swallow reflex coordination… Continue with progressive
exercise training with increased reps x 10 of minimal pair sets and lingual resistance training
for increased lingual strength.
Keep discussion and administration of exercise regimens and overall dysphagia treatment
provision progressive in nature. If treatment does not seem to progress, modifications may be
Lack of Goal Modifications
Sometimes goals are just right progress flows from evaluation through discharge. Other times,
modifications are needed. If patients are not progressing, evaluate the plan of care. Do goals
account for lower levels of functioning? If the patient has progressed beyond their goals, they
may require an upgrade toward long term goals and higher levels of function. Demonstrate the
skilled ability to analyze patient functionality and adjust the plan of care accordingly. At the end
of each period, use the progress note to communicate what occurred and the plan moving
forward, goal modifications or not, to demonstrate a clear and meaningful direction. If
documentation reflects the daily clinical rationalizations of treatment; it will speak for
From start to finish, solid dysphagia documentation describes the patient’s change in function,
notes the disease processes that led to that change, and details the plan for correction or
compensation as it occurs, noting the clinical rationalizations along the way. Demonstrate the
skill and complexity of these services to facilitate appeals success.
About the Author
Anna Eakins, MS, CCC-SLP is an Appeals Specialist with RehabCare. A graduate of the
University of Kentucky, Anna has worked in long-term care as a Speech Pathologist and
Program Manager since 2006 with special interests in dysphagia, dementia, documentation,
Medicare regulation, and compliance.
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courses click here
American Speech-Language Hearing Association. (2011). Speech-Language Pathology Medical
Review Guidelines. 16.
Centers for Medicare & Medicaid Services. (2014). Covered Medical and other Health Services.
Medicare Benefit Policy Manual, Chapter 15, 164-184. (CMS Publication No. 100-02).
Retrieved February 9, 2015, from
Wisconsin Physicians Services Corporation. (2015). Skilled Nursing Facility (SNF) Common
Reasons for Denial. Retrieved February 8, 2015, from