SNF PPS Final Rule FY2012: Strategies For The Transition
The SNF PPS FY2012 Final Rule (76 FR 48486) outlined several policy changes in the SNF PPS effective for FY 2012. These changes include: a revised MDS assessment schedule, the Change of Therapy (COT) Other Medicare Required Assessment (OMRA), a resumption of therapy option for the End-of-Therapy OMRA, the allocation of group therapy time, and a revised student supervision policy. CMS has posted a transition document for implementation of these changes scheduled for October 1, 2011.
SNF PPS MDS Schedule: In order to reduce overlap between assessment look-back periods, effective for FY 2012, facilities will utilize a revised MDS assessment schedule.
Transition Strategy: MDSCs and Rehab Staff members need to establish a set meeting time that will occur on a daily basis to discuss target ARDs and adjust the ARD selection as necessary. Therapy professionals should begin to schedule and map minutes based on the new PPS MDS schedule as soon as possible. Post the updated PPS MDS schedule for all nursing and therapy staff to see on a daily basis to influence familiarity and memorization of the new available dates.
Change of Therapy OMRA: For all Medicare Part A SNF residents, a COT OMRA is required if the therapy services a resident receives during the COT observation period do not reflect the RUG-IV classification level given on the patient's most recent PPS assessment used for payment and would instead cause the patient to be classified into a different RUG category.
Transition Strategy: Harmony recommends review of PPS assessments that will have the option of ARD selection in September or October. Any assessments that can be completed prior to October 1, 2011 will ease the amount of COT assessments in October.
Revised SNF End-of-Therapy (EOT) OMRA: Prior to FY 2012, a distinction was made between facilities that "regularly" provided therapy services 5 days per week versus those that "regularly" provided therapy services 7 days per week for the purpose of setting the ARD for an End-of-Therapy (EOT) OMRA. Beginning in FY 2012, all facilities will be considered 7-day facilities regardless of the scheduled days of therapy treatment.
Transition Strategy:Prevention of the EOT OMRA is the best approach to avoid interruption in PPS payment levels. Heightened communication amongst team members will provide a solid defense to the newly implemented EOT guidelines. The Rehab department operations will require scrutiny to determine if the necessary coverage is in place to shift patient treatment schedules when a conflict arises. Hours and days of operation are a major consideration. The Rehab Team should prepare to offer services between 7AM and 8PM, as well as 7 days per week. Barriers to treatment should be discussed with education provided for any consulting Medical professionals regarding the priority to maintain the therapy appointments. This can assist in avoiding conflicts with physician visits and outside medical treatments.
Additional strategies will be discussed in the next Harmony Newsletter.
The Transition Policy Memo can be located at the CMS web page listed below:
RAI Manual updates can be found at the following page:
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