Harmony Healthcare Blog

SNF PPS FY 2012; Final Rule Considerations and Preparations

Posted by The Harmony Team on Fri, Aug 12, 2011

PPS, MDS 3.0, Final RuleSNF Leaders do not have a long lead time between July 27 and October 1 when SNF PPS changes posted in the Final Rule go into effect.  The next two months will be filled with reading and re-reading the SNF PPS Final Rule, working on assimilating and interpreting the planned changes as well as participating in the CMS ODFs and web education to confirm each facet of this complex reimbursement program. Language in the Final Rule regarding MDS 3.0 guidance, billing allowances and documentation requirements can easily be misinterpreted.


Team meetings are essential at this time to allow the Medicare Team to review new requirements, strategies for implementation and schedule education for the entire SNF staff.


What to Consider?

  1. How will the team incorporate the new the MDS assessment window schedule to avoid payment of default days?
  2. Who will be primarily responsible for tracking rehab provision of care to monitor minutes, days and RUG classification requirements?
  3. What type of systems will need to be implemented to monitor rehab service delivery?
  4. Who should the Facility or Center contact to get answers to questions left unclear in Final Rule language? CMS directly, the MAC, state RAI Coordinator, software vendor or outside consulting agency?
  5. Skilled therapy delivery and nursing skilled care oversight to maintain the Medicare Part A revenue stream.
  6. Where to begin? 

How to Prepare:

  • Schedule on a minimum, biweekly meetings to outline and discuss upcoming systems changes.
  • Review and post the new MDS assessment schedule options for the team to memorize immediately.  
  • Educate Therapy professionals on the new definition for group therapy, documentation requirements and mode of therapy billing revisions scheduled to be implemented October 1. 
  • Select a leader to begin auditing rehab minutes and days of delivery to identify patterns which will impact reimbursement come October 1 under the new guidelines.
  • Obtain and implement the tools necessary to accurately track therapy minutes and days that fall below or exceed the planned RUG category. (Tools should flag significant overages or missed minutes that will effect reimbursement levels).
  • Track and analyze therapy productivity. 
  • Schedule mandatory education for all nursing staff focused on Medicare Part A skilled care coverage criteria including RUG classifications and Medicare eligibility and entitlement.   

Time is of the essence to solidify solutions within the SNF geared toward compliance and reimbursement for the Medicare Part A program.  Harmony Healthcare experts are working closely with our clients to manage this transition with the utmost efficiency.  Contact Harmony to get answers to any questions or barriers your facility may have.


CMS has posted a transition document for implementation of changes scheduled for October 1, 2011. To access this document cut and paste the link below:



Find out Today how Harmony Healthcare is helping their Clients Prepare for the upcoming Changes!!!!!



Topics: Final Rule, SNF, CMS, MDS, PPS

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