On March 9, 2016, The Centers for Medicare and Medicaid Services (CMS) announced the release of their public data set called the Skilled Nursing Facility Utilization and Payment Public Use File (PUF). This report is released as part of the Administration's efforts to make the healthcare system more transparent, affordable and accountable. The Skilled Nursing Facility PUF contains information on utilization, payment, and submitted charges and is organized by the CMS Certification Number, Resource Utilization Group (RUG) and state of service. The recently released report contains information about calendar year 2013. CMS acknowledges that this data has limitations, as it does not address the quality of care provided by individual Skilled Nursing Facilities. The report contains only utilization information and the data is not risk adjusted to account for differences in the underlying severity of diseases of patient populations treated by providers.
The report includes several tables, which group the data by RUGs, by state, and by number of therapy minutes provided. The SNF PUF data allows for many types of analyses to be performed, including summary analyses by RUGs billed. Results of this data show that for calendar year 2013, the RUG with the highest total Medicare payment was the RUB with 15,801,830 total days provided. The second highest RUG was the RUC, with 11,731,618 total days provided. The third highest RUG was the RUA, with 8,129,548 total days provided. Rounding out the top ten were the RVC, RVB, RVA, RHC, RHB, RHA, and the RMC.
The data in this report is also useful for geographical comparisons of costs and utilization of SNF services. For CY2013, the average standardized payment amount per stay for all SNFs was $10,919, with an average length of stay of 28 days. The data collected in the SNF PUF reveals that the states with the highest average standardized payment amounts were Indiana ($12,406), Texas ($12,064), and California ($11,862). The states with the lowest per stay payment amounts were North Dakota ($8,154), Maine ($8,959), and Alaska ($8,854).
Information about the therapy minutes provided on the highest-utilized RUGs can also be gleaned from this report. The report reveals that for the highest-utilized RUGs, many beneficiaries received minutes that were within 10 minutes of the RUG classification threshold. For example, the minute threshold for a Rehab Ultra High (RU) RUG is a minimum of 720 minutes. Information provided by this report reveals that of all RU level RUGs provided in calendar year 2013, 65 percent showed therapy provision between 720-730 minutes. For the Rehab Very High (RV) RUG, the minute threshold is a minimum of 500 minutes. Information provided by this report reveals that of all RV level RUGs provided in CY2013, 51 percent showed therapy provision between 500-510 minutes. CMS has taken note of this trend, and is providing approval to the Medicare Fee-For-Service Recovery Auditor Contractors (RACs) to investigate this issue. The primary concern of CMS in light of this information is that the provision of therapy is being driven by payment incentives, and not by patient need. States in the Midwest and Texas had a high percentage of RV assessments that fell within the 10 minute mark of the threshold. The Southwest had notably high percentages of RU assessments that fell within the10 minute threshold, as did California, Nevada and a few Southeastern states.
Harmony Healthcare International (HHI) recommends that providers clearly demonstrate, through accurate and detailed documentation, the clinical need for the therapy minutes provided to each beneficiary. Targeting strict thresholds of minutes or overage limitations and/or incentives does not reflect clinically based therapy provision. Therapy provision should always be based on the clinical need of the patient, and should be set at whatever level allows the patient to meet their recovery goals and achieve a safe discharge to a lower level of care.
The fact sheet summarizing the report may be accessed through the CMS website. There is a link in the fact sheet that will direct the viewer to the full report.SNF PUF data, please contact Harmony Healthcare by clicking here or calling our office at (800) 530-4413.