From the Desk of Kris Mastrangelo:
The Final Rule results are pretty much what we expected. The Rates were definitely much higher than anyone anticipated last October 2010 (FY 2011) with the implementation of the RUG-IV versus the RUG-III Hybrid.
Harmony is confident that through our auditing process we will be able to lessen the negative impact on our customers if not continue with increasing the Rate and Revenue. The medical record review process is a critical piece in ensuring optimal reimbursement. In addition, this process allows one to simultaneously insulate the facilities from governmental take backs. In 2011, Harmony advised the facilities to stay somewhat conservative on driving the revenue from a therapy case management perspective. This is primarily due to the fact that governmental audits are more frequent when rates are robust. One of the many metrics addressed included the therapy percentage of Ultra High Therapy RUGs days. Harmony re-established the RU% benchmark. This metric is frequently used to determine focus faciltities by CMS.
With the implementation of the 11% payment reduction, Harmony will modify benchamarks and redesign the desired case mix RUGS distribution. An 11% global Rate decrease can be successfully offset within the management of the facility specific RUGS profile.
As far as the clinical changes with regards to groups, end of therapy OMRA’s, etc, it appears the government is changing the rules as we go. In other words, it is no longer a “prospective system” given the ongoing adjustments that need to be made with rolling ARD’s and End of Therapy Assessments. There are other variables as well that Harmony will focus on to ensure the Medicare Part A Rates and the Medicare Part A Total Revenues stay healthy.
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