disclosure of commercial interests - achca.memberclicks.net · hospital or ltch who have a...
TRANSCRIPT
4/15/2018
1
Disclosure of Commercial InterestsI have commercial interests in the following organization(s):
• Celtic Consulting, LLC• President• Celtic Consulting is a nationally recognized long-term care advisory firm, focused on
providing one-on-one oversight, to facilities of all sizes.
Medicare Changes for the Administrator: How Quality, Value and a New Payment System Impact Your Bottom Line
Presented By:Maureen McCarthy, RN, BS, RAC-MT, QCP-MT
President of Celtic Consulting
Maureen McCarthy RN, BS, RAC-MT, QCP-MT
Maureen is the President of Celtic Consulting, LLC and the CEO and Founder of Care Transitions, LLP. She has been a registered nurse for 30 years with experience as an MDS Coordinator, Director of Nursing, Rehab Director and a Medicare biller. McCarthy is a recognized leader and expert in clinical reimbursement in the skilled nursing facility environment. She is dually certified in both the resident assessment process and QAPI by nationally recognized organizations and holds Master Teacher status in both and is a board member of American Association of Post-Acute Nurses (AAPACN) and is an Expert Advisory Panel member for American Association of Nurse Assessment Coordination (AANAC).
Maureen and her associates at Celtic Consulting regularly provide the following services for SNFs, state affiliates and provider organizations:
• 5 Star Quality Improvement Program• Quality Auditing• Clinical Care Management• RCS/PPS/MDS/CMI Services • Compliance Solutions• Medicare Compliance Auditing• Customized Education / In-Services
4/15/2018
2
Objectives• Explain Medicare’s Value Based Purchasing (VBP) and how
to program is funded and monitored.• Understand the three new Quality Measures being
collected now for 2018 use.• Differentiate between 5-Star and Quality Reporting (SNF
QRP).• Prepare for the shift to a condition based payment system.
SNF Quality Reporting ProgramSection GG Updates 2017What you should be doing now!
Improving Medicare PAC Transformation Act of 2014
• This Act is more detailed than Triple Aim and calls for:– Data element uniformity (standardized assessment and data)– Quality care and improved outcomes– Comparison of data across continuum– Improved discharge planning– Exchangeability of data– Coordinated care
• Phased in over 5 years through 2020• CMS is required to report data within 2 years of inception
of the measures
4/15/2018
3
SNF QRP
IMPACT Act
Improve Outcomes
Improve Care
Coordinati-on
Allow Comparis
onsResearch
Improve DC
Planning
QMs for SNFQRP under IMPACT • MDS-Based Measures:
– Functional status and cognition changes from admit to d/c (10-1-16)
– Skin integrity and changes: new or worsening pressure ulcers (10-1-16)
– Falls with major injury (10-1-16)– Care Plan- communication of health info (10-1-19)– Medication reconciliation (10-1-18)– GG goals met/ Admission-to-Discharge Performance
improvement (10-1-18)• FY17 Claims-Based Measures 2017• MSPB-Medicare Spending per Beneficiary• Discharge to community, • Potentially Preventable re-hospitalization
SNF QRP QMs Newly IMPACTing Payment FY2019
Claims-Based Quality Measures
Medicare Spending per Beneficiary
(MSPB)
Discharge to Community
Potentially Preventable 30-
Day Post-DC Readmission
(PPR)
4/15/2018
4
SNF QRP Claims-Based Measures
Potentially Preventable Readmissions • Slight variation on the rehospitalization QM reported in
Five Star• Only Medicare Part A• Time period = 1st 30 days following Discharge from SNF
excluding day of Discharge • Measures readmission rates for those readmitted to a
hospital or LTCH who have a principal diagnosis considered to be unplanned & potentially preventable.
What’s Potentially Preventable?
• Respiratory: COPD, asthma, aspiration PNA, bacterial PNA, flu
• Cardiac: CHF, hypo/hypertension, some arrhythmias• Some diabetic complications• Skin/Subcutanous: pressure ulcers, infections• Septicemia• GI/GU: UTI, Cdiff, dehydration, gastroenteritis, acute
kidney failure, electrolyte imbalances, intestinal impaction
SNF QRP Discharge to Community• Slight variation on the DC to community QM reported in
Five Star• Only Medicare Part A• Time period = 31 days post discharge to community• Measures SNF rate of successful discharge through no
unplanned rehospitalizations nor death in the 31 days (includes day of discharge)
• Discharge status codes on the SNF claim are important here– Only these four codes are considered - O1, 02, 81, 86
(82-planned d/c Acute) – Does your team communicate with finance on this?
4/15/2018
5
SNF QRP Medicare Spending per Beneficiary (MSPB)
• Also claims-based, Part A only but includes spending for both A&B• CMS Goals for this measure include:
– Improve care coordination & efficiency of care– Facilitate comparisons while accounting for case mix – Create accountability amongst providers for quality & value by
measuring resource use for an entire “episode” of care• Calculates both Attributor Provider & other Provider services costs
throughout the episode which begins on admit & for 30 days after discharge
• Episodes are only compared to other episodes of like providers
SNF QRP Medicare Spending per Beneficiary (MSPB)
• Exclusions of Clinically unrelated services including:– Planned hospital admissions– Routine management of certain preexisting chronic conditions– Some routine screening and health care maintenance– Immune modulating medications
• Beneficiary must have been enrolled in Medicare Part A for the entire 90-day period prior to admission date for episode & for entire episode window (Part A stay through 30 days from discharge.)
• Will have risk-adjustments r/t prior care/services, age, clinical categories, etc.
MSPBMeasure calculated by comparing your SNFs Medicare spending to other providers nationally of the same type during the performance period.
If provider’s value is >1 = Medicare spending was higher than the national median spendingIf provider’s value is <1 = Medicare spending was lower than the national median spending
4/15/2018
6
MSPB Example
Claims-Based Reports
• Confidential Feedback Reports begin October 2017– Using claims for CY2016
• Public Reporting begins October 2018– Using claims for CY2017
4/15/2018
7
SNF QRP QMs Currently IMPACTing Payment
MDS-Based Quality Measures
New or Worsened Pressure
Ulcers
Falls with Major Injury
Adm & DC Functional
Assessment with Care Plan
SNF QRP Section GG RAI/MDS Coding• Primarily updated the RAI to include CMS clarifications • Responses to gateway questions for walking & WC use do not
have to be the same on both Admission and DC Performance.• DASHES: never dash a “Performance” column, only allowed in
“Goal” column as long as you’ve chosen at least one goal• Will be adding codes to MDS 10/1/18 to address coding GG
goals
SNF QRP MDS-Based Reporting
4/15/2018
8
4/15/2018
9
4/15/2018
10
Collecting Facility Data & Reports• Subsequent Review and Correct Reports:
• After the first quarter, subsequent reporting quarters data are added. • Cumulative data are displayed & 80% compliance is required for the entire reporting year.• When a new reporting year begins, the oldest quarter is dropped (i.e., rolling quarters).
• Calculations of compliance for assessments that straddle a reporting year will be counted toward the reporting year in which they occur:
– 5 Day & 14 Day PPS 12/2017 and DC MDS 1/5/18. If new/worsened pressure ulcer occurs in Jan. but not December, each will count in their respective reporting period
• CMS will not be providing details on QRP data. Providers will need to use existing available reports.
• Review & Correct Reports update Monday in early AM• Data calculated on 1st day of the month after quarter closes
4/15/2018
11
Model language for initial notification letters: “This letter is to officially notify you that (Facility Name, CMS Certification Number 000000) is subject to a reduction in payment for not meeting section IMPROVING MEDICARE POST-ACUTE CARE TRANSFORMATION ACT OF 2014 (IMPACT Act), Section 1888(e) of the Social Security Act (42 U.S.C. 1395yy(e))requirement for SNFs to submit quality data. Therefore, Medicare payments to your facility will be reduced by two (2) percentage points for [insert upcoming year]; unless you can provide evidence that this determination is in error. CMS updates the requirements and the quality reporting measures required for the SNF Quality Reporting Program (QRP) annually through rulemaking. CMS has determined that this SNF is subject to a 2% reduction in the FY (insert upcoming year) annual increase factor for failure to meet quality reporting requirements pursuant to the Impact Act Section 1888(e) because of the following reason(s): • The SNF failed to submit the required quality measures that are to be submitted to the CMS Quality Improvement Evaluation System (QIES) system.
If you believe you have been in compliance with the quality data reporting requirement and have been identified for this payment reduction in error, you must submit an email requesting reconsideration and provide documentation demonstrating your compliance. You have the right to request a reconsideration of this decision. If you choose to request a reconsideration of this decision, you must submit the request no later than 30 days following the receipt of this letter.
Tips for Managing QRP Compliance – Section GG• Strengthen facility documentation related to GG Functional
performance. Ensure “usual” performance determination is documented to account for fluctuations in the assessment period.
• Consider goals attainable by the End of PPS stay which often differs from the ultimate long term functional goal.
• Make Functional performance & goals a topic in weekly Medicare meetings.
• If you are only choosing 1 goal, start choosing at least 1 goal in each category (Self-Care & Mobility.)
• Track goals, gather data related to those met and those not met, analyze for possible PIPs.
Tips for Managing QRP Compliance
• Know how MDS completion affects QMs; comply with MDS timely completion & submission requirements.
• For claims-based measures, develop a process to ensure appropriate review of discharge status codes. How is this communicated?
• For DC & readmission QMs, develop/review processes to transition & coordinate care with other care settings.
• For MSPB, review claims process for accurate reporting of resource use.
• Strengthen clinical assessment and skills. Analyze events for improvement opportunities.
• Utilize available reports to review & correct, where applicable.
4/15/2018
12
Reports to Assist with QRP Auditing
• Validation Reports• SNF QRP Review & Correct• MDS Missing Assessment report• MDS Error Detail by Facility report• Assessments with Error Number XXXX report (use 3863
for GG goals.)• Admission/Reentry Report• MDS Discharges Report• Facility MDS software reports
SNF QRP Preview 10/1/18For FY2020
• Drug Regimen Review (medication reconciliation)
• Changes in Skin Integrity PAC: Pressure Ulcer/Injury
• Change in Self-Care Score for Medical Rehab Patients
• Change in Mobility Score for Medical Rehab Patients
• Discharge Self-Care Score for Medical Rehab Patients
• Discharge Mobility Score for Medical Rehab Patients
4/15/2018
13
MDS Updates: October 1, 2018
Prior Functioning in Everyday Activities:• Self Care• Indoor Mobility• Stairs• Functional Cognition
Prior Device Use including:• Lifts• Orthotics/Prosthetics
Expands Section GG Self-Care
Expands Section GG: Mobility
4/15/2018
14
Expands Section GG: Mobility
New GG Choices for Goals
And, don’t forget: Drug
Regimen Review
4/15/2018
15
Quality Measure TIP- Rehospitalization Focus
QRP
5 Star
VBP
SNF Value-Based PurchasingThe Next CMS Initiative
SNF Value Based Purchasing
• Part of Protecting Access to Medicare Act of 2014 (PAMA)• Program begins FY 2019 (10/1/18)• Concept calls for providers to show their ‘value’ by reducing
costs, so CMS is buying good ‘value’ with their Medicare dollars. Currently, measures are based on re-hospitalizations.
4/15/2018
16
SNF VBPResult of PAMA of 2014 enacted 4-1-14 under Social Security Act• Focus of the program:
– Performance standards including ‘achievement’ and ‘improvement’ ratings
– Rank SNFs for from low to high based on performance– 2% of PPS/Medicare payment withheld to fund program– Incentive payments to providers must total 50-70% of amount
withheld– Incentive payments=buying your money back, up to 2%
• Both measures are based on hospital readmissions– SNF PPR- potentially preventable, risk adjusted (will replace RM)– SNF RM- all-cause/condition, original measure (begins 1-1-17)
• Payments affected 10/1/18
SNF VBP Re-hospitalization Measure RM
‘Improvement’ Rating up to 90 points
________________ 2017 your SNF
________________ 2015 your SNF
Better of the two, Improvement Rating or Achievement Rating
SNF VBP Re-hospitalization measure RM
• If your SNF meets the BENCHMARK, then your rating is 100. • If your SNF doesn’t meet at least the 25th percentile, then your rating is 0.• Remainder will be disbursed, 0-99.
_______________ 2017 your SNF
_______________ 2015 ALL SNFs
Benchmark: Average top 10% performing SNFs in 2015 (83.6)
Achievement Rating: SNF reaches 25% threshold (20.41)
4/15/2018
17
SNF VBP Measure• Results in achievement rating score based on percentage of residents
that were not readmitted during the window• Compares value rating scores between providers• How did you do in 2017 compared to all SNFs nationwide in 2015?
– If you did better than benchmarks (100 points)– If you did worse than achievement threshold (0 points)– All facilities in between points assigned based on “Achievement
Score”• Second score “Improvement Score” based on how well your facility did
in 2017 compared to your 2015 data – Above benchmark (90 points)– If worse than 2015 (0 points)
Performance Scores
The lower the readmission rate, the better.
Since a lower readmission rate is better, CMS has inverted every SNF’s readmission rate using (1 –readmission rate) for the purposes of the performance standards (i.e., benchmark and achievement threshold) and performance scoring.• Standard 2015• 25th Percentile 20.41%• Achievement Threshold 79.59%• Mean of the Best Decile 16.40%• Benchmark 83.60%
2015 Performance Data
4/15/2018
18
Risk Adjustment
• Example risk adjustment variables include the following (List is not all inclusive): patient demographics (e.g., age and sex)
• principal diagnosis in the prior hospitalization• comorbid conditions• disability as the original reason for Medicare coverage• health service factors (e.g., length of stay and any time spent in
intensive care unit during the patient’s prior proximal hospitalization)
• https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/Other-VBPs/SNF-VBP.html.
Excluded Re-hospitalizations
SNF stays where: There was an intervening post-acute care admission within the 30-day measure window• There was more than 1 day between the prior proximal
hospital discharge and the SNF admission• The patient was discharged from the SNF against
medical advice• The principal diagnosis from the prior proximal
hospitalization was for pregnancy• The principal diagnosis from the prior proximal
hospitalization was for medical treatment of cancer
Potential Additions to the Provider ReportsPatient-level data elements currently being considered for inclusion include:• Patient identifiers (Health Insurance Claim Number [HICN], Sex, Date
of Birth)• Index SNF information (admission/discharge dates, discharge status
code)• Prior proximal hospital information CMS Certification Number [CCN],
admission/discharge dates, discharges status code, principal diagnosis)
• Readmission hospital information (CCN, admission/discharge dates, principal diagnosis)
• SNFRM risk-adjustment factors
4/15/2018
19
Supplemental Workbook -Eligible Stays tab-21
PATIENT CHARACTERISTICS INDEX SNF INFORMATION PRIOR PROXIMAL HOSPITAL INFORMATION
ID Number
HICN Sex Age
Admission Date of
Index SNF Stay
Discharge Date of
Index SNF Stay
Index SNF Discharge
Status Code
PriorProximalHospital
CCN
Admission Date of Prior
Proximal Hospital
Stay
Discharge Date of Prior
Proximal Hospital
Stay
ICD Version of Principal Diagnosis
(Prior Proximal Hospital)
Principal Diagnosis of
Prior Proximal
Hospital Stay
Modifying Data
It is the responsibility of each SNF to provide corrections to information prior to the time of public reporting.•CMS has finalized a process where the quarterly reports will provide SNFs with:• A count of readmissions• The number of eligible stays at the SNF• The SNF’s risk-standardized readmissions rate • The national SNF measure performance rate
SNF VBP Preview Reports
4/15/2018
20
Modifying Data
• For the first phase, SNFs must submit correction requests for their quality measure data to [email protected] and provide the following:
• CMS Certification Number• Facility name• Correction requested and basis for the correction• Appropriate documentation or other evidence supporting
the request
Modifying Data
• Phase One corrections are limited to review and correction of SNFs’ quality measure information.
• Phase Two corrections are limited to SNF’s performance scores and ranking.• CMS will propose more specific requirements for Phase Two corrections in
the future, and welcomes feedback.• Correction requests to the contents of any quarterly report will be accepted
until March 31 following the report’s delivery.
If corrections are provided after information is publicly reported but before the March 31st deadline, corrections will be made retroactively. CMS will review the requests and notify the requesting SNF of the final decision.
Retrieving SNFVBP Reports
4/15/2018
21
Provider Reports
Resident Classification System (RCS-1)
Resident Classification System (RSC-1)
• PPS is resource use based, incentivizing use of rehab therapy for higher revenue– Rehab RUG levels became targets
• Complex medical admissions support therapy• CMS will create disincentive for SNFs to push up rehab RUG
levels
• RCS will be based on resident conditions
4/15/2018
22
FY 2018 Rate Methodology
• Market basket changes– Predicted an increase of 2.7% and no Productivity adjustment
due to prior year showed no increase• 2016 market basket 2.3, actual increase 2.3 =0% change
– Actual market basket increase of 1% • CMS implemented a Special Rule stating that the FY 2018 market
basket must equal 1%• No Multi Factor Productivity adjustment applied (0.4%)
– May also subject to 2% reduction related to SNFQRP data under 80% of total MDSs & 2% VBP
• Wage Weighted Staff Time– Based on 2014 Nursing RUGs (43)
Wage Weighted Staff Time
• STRIVE data separated by resident specific time (direct care) and job title=nursing costs
• Sample size limited to 2,310 stays, most MACs do not reimburse in lower 14 nursing RUGs
• Applied to each non-rehab RUG (43) for FY 2014• Average CMI was set to 1.0
4/15/2018
23
FY 2018 Rate Structure
FY 2019 Rate Structure
FY 2018 Rate Methodology
• 2014 claims data was extrapolated to study SNF billing patterns and resident characteristics and learned where costs decreased or leveled off and what resources were used through the length of stay– Diagnoses, length of stay, ARDs, RUG level per
beneficiary
4/15/2018
24
FY 2018 Rate Methodology
• Acumen research linked costs to beneficiary characteristics then verify via provider info using cost reports and wage data to estimate beneficiary costs
• Normalized for all SNF sizes• Cross referenced via CASPER reports• Backed into costs using CCR from cost reports
– Cost-to-charge ratios
FY 2018 Rate Methodology
• Do you include all charges on claims by revenue code? $58/day higher than average– IVs separate from drugs– Specialized services
• Hyperbaric chambers• Wound supplies• Enteral feeding supplies
• Did you have accurate diagnosis codes? or….• V57.89 Multiple therapies
Cost of Inaccurate Diagnoses
• Prior hospital stay diagnoses used because 47% of providers used generic procedure codes rather than diagnosis codes like V57.98 (multiple therapies)
• Does not reflect primary reason for skilled care, irrelevant to describe resident condition
4/15/2018
25
Diagnosis & Conditions –Applicable to
RCS-1 and SNF QRP
Co-morbid Conditions
• Diagnoses mapped to condition categories (clinical groupings)
• Data obtained through MDS assessments and 1 year look back to other providers (MD, Hospital, OPT) to identify chronic conditions
• ICD-9 codes (2014)
Co-morbidity Score
• A count system will be summed to assign payment rates based on the number of comorbidities present and based on the number of comorbid conditions and costs– Higher payments for those with more co-morbidities
• Diagnosis coding!!!• NTA costs higher for those with higher multiple comorbid
conditions
4/15/2018
26
FY 2018 Rate Methodology
• Base Rate + CMI + Adjustment factor• CMI dependent on resident classification assigned
– Nursing– PT/OT– SLP– NTA
RCS-1 Rates Urban-
example
$100.91 X Nursing RUG CMI =
76.12 X NTA CMI X Adjustment Factor =
126.76 X PT/OT CMI X Adjustment Factor =
24.14 X SLP CMI =
90.35 X 1= 90.35 (Non-case mix component)
RCS Payment
Calculation
4/15/2018
27
PT/OT
• Based on hospital diagnoses– Separated surgical DRGs from medical DRGs– Surgical further divided by Ortho and Non-ortho
• Cognitive status• Functional status
SLP
• Based on hospital diagnosis– Cognitive status– Speech related co-morbidities– Swallowing problem– Mechanically altered diet
SLP Related Co-morbidities
4/15/2018
28
Nursing
• Based on clinical diagnoses from SNF stay• End Splits
– Extensive services– Depression– Restorative nursing
NTA
• Non-Therapy Ancillary Services• Based on co-morbidities• Extensive Services
– Isolation– Tracheostomy– Ventilator
Non-case Mix
• Therapy evaluations• Other items related to therapy for non-rehab RUG groups• Room and Board
4/15/2018
29
Adjustment Factor
• Claims showed that costs reduced depending on LOS• Variable per diem schedule based on day of stay• Will reduce PT/OT by 1% per day after day 14
– So day 15 will be day 1 with a 1% reduction through day 100 (71%) of PT/OT costs
• NTA costs drop after day 3 ($150 vs $47/day)
4/15/2018
30
RCS-1 Rate Structure
Nursing: 100.91x 2.27 (HE2) $229.06+
NonTherapy Ancillary 76.12 (NTA) x 3 (adj) $228.36+
PT/OT: 126.76 (PT/OT) X 2.73 (TC) X .99 (adjustment factor day 17) $342.59+
SLP: 24.14 (SLP) X 2.54 (SF) $61.32+
Non-Case Mix: 90.35
Total Rate= $951.68
Clinical Condition Categories
PT/OT Clinical Categories
4/15/2018
31
Diagnosis Crosswalk
Diagnosis Crosswalk
Cognitive Function Scale
Combines BIMS and Cognitive Performance Scales to compare cognitive function across all residents
– Makes self understood– CPS (coma, ST memory,
decision making, ADL)– BIMS (interview or
assessment)
4/15/2018
32
Functional Score PT/OT
• Based on 3 ADLs (Bed Mobility eliminated)• Range 0-18
– Therapy costs increased then decreased with greater dependence in regard to toileting and transfer
– Costs increased with independent level for eating– Limited assist resulted in highest PT/OT costs (6pt)– Extensive assist, results in 5 points
Functional Scoring
• 3 of the 4 late loss ADLs will be used to determine functional score
• Bed Mobility is not utilized• Only Self Performance is used, Support is ignored• Uses ‘Activity Happened Once or Twice’ (7)• Uses ‘Activity Did not Occur’ (8)
PT/OT Functional Score: Transfer/Toileting
4/15/2018
33
ADL Points for Functional Score
Classification and Regression Tree
• First start with clinical reasons using 1st line on Section I diagnosis coding– This will be the field for primary diagnosis
assignment • Then for PT/OT the Functional score is determined,
then Cognitive Functional Score• For SLP, the presence of a swallowing
disorder/mechanically altered diet, SLP comorbidity, then cognitive impairment
CART Regression Assignments for Final Group
• 30 case-mix groups for PT/OT• 18 case mix groups for SLP• 43 case mix groups for Nursing• Total of 91 possible CMI groupings • 6 NTA add-ons
4/15/2018
34
CART for PT/OT
CART for SLP
4/15/2018
35
CART for SLP
Classification and Regression Tree
• First start with clinical reasons using 1st line on Section I diagnosis coding– This will be the field for primary diagnosis assignment
• Then for PT/OT the Functional score is determined, then Cognitive Functional Score
• For SLP, the presence of a swallowing disorder/mechanically altered diet, SLP comorbidity, then cognitive impairment
Nursing CART Assignment
• First assigns the Non-rehab RUG assignment• Then assign weights for WWST (wage weighted staff time)• Apply end-splits
– ADL score– Depression score– Restorative nursing
4/15/2018
36
CART for Nursing
NTA Classification
• 2 tier assignment• Uses both resident conditions or diagnoses• Then determines use of extensive services
4/15/2018
37
Determine NTACase Mix Group
using Score Total for all
Comorbidities
NTA Score Range NTA Case-Mix Group NTA CMI
11+ NA 3.33
8-10 NB 2.59
6-7 NC 2.02
3-5 ND 1.52
1-2 NE 1.16
0 NF 0.83
NTA Comorbidities with Highest Points
• HIV (8 points)• High-Intensity Parenteral/IV Fluids (7 points)• Low-Intensity Parenteral/IV Fluids• IV Medication• Ventilator Use
(5 points)
4/15/2018
38
Adjustment Factors-NTAPT/OT
NTA Adjustment Factor
RCS-1 Rate Structure
Nursing: 100.91x 2.27 (HE2) $229.06+
NonTherapy Ancillary 76.12 (NTA) x 3 (adj) $228.36+
PT/OT: 126.76 (PT/OT) X 2.73 (TC) X .99 (adjustment factor day 17) $342.59+
SLP: 24.14 (SLP) X 2.54 (SF) $61.32+
Non-Case Mix: 90.35
Total Rate= $951.68
4/15/2018
39
MDS
• Version 1.16 will have multiple changes related to RCS and new QMs for SNFQRP
• Transition/Effective date 10/1/18• ADLs used for Non-rehab RUGs for Nursing component• Functional score used for PT/OT component• Will add a section for Primary diagnosis
MDS Schedule
Interrupted Stay Policy
• Discharge of less than 3 days will not require a new MDS, same RCS level will continue
• Payment will resume at prior RCS,(same SNF)• Significant Change will take precedence and allow
changes to RCS level• Must meet same clinical criteria to perform SCSA • Discharge to new provider will restart with 5-day
4/15/2018
40
Interrupted Stay Policy
• Readmission to the same SNF after discharge 3 or more days, will require new 5-day MDS
• NTA is reset to initial adjustment factor (Day 1)
Highest Paying RCS• Acute Neurological with both swallowing problem and
mechanically altered diet• Average of $130.14 with CMI 4.19• Total add-on for all 3 therapy disciplines
– $387/day which is higher than RUG IV at approximately $249/day
• May want to utilize therapy provision in a similar way to managed care– We can afford to spend X amount based on reimbursement
Questions??
Maureen McCarthy, RN, BS, RAC-MT, QCP-MTPresident, CEOPhone (Office): 860-321-7413Email: [email protected]
www.celticconsulting.org