Compliance • Audits/Analysis • Reimbursement/Regulatory • Education/Efficiency
CMS (Centers for Medicare and Medicaid Services) just made available details of the proposed payment system in a document called the Advanced Notice of Proposed Rulemaking. The document defines the proposed revisions to the currently used Case-Mix Methodology with time for public feedback and opinions on the possibility of replacing the SNF PPS existing Case-Mix Classification Model, Resource Utilization Groups, (RUG-IV) Case Mix Classification Model with the Resident Classification System, Version I (RCS-I). Comments must be received no later than 5 p.m. on June 26, 2017.
The revised model, the Resident Classification System, Version I (RCS-I), will case-mix adjust and be grouped into four major cost categories (See below).
- Transition from Resource Utilization Groups (RUG-IV) to Resident Classification System (RCS-1).
- Change from Rehabilitation and Non-Rehabilitation RUGs levels (66 Levels) to Resident Classification in 4 categories:
- Physical Therapy (PT) / Occupational Therapy (OT)
- Speech Language Pathology (SLP) Services
- Nursing Services
- Non-Therapy Ancillaries (NTAS)
- The PT/OT and SLP components will be determined based on Resident Characteristics, not Therapy Days and Minutes.
- Nursing Classification will align with Current Nursing RUG Levels.
- MDS Diagnosis Coding Accuracy is critical.
- Proposed System will base reimbursement on the 5-Day MDS Assessment Only and all other PPS assessments eliminated.
- Reclassification for a Significant Change in Status will occur with completion of a Significant Change in Status Assessment.
- The Resident Classification covers the entire Medicare stay unless a Significant Change in Status Assessment is performed.
- Reimbursement rate will be adjusted throughout the Medicare Covered Stay with decreasing rate accounting for utilization of fewer resources as the stay extends.
- A patient re-hospitalized for greater than 3 days will have a new 5-Day MDS Assessment completed to reclassify.
- A re-hospitalization of less than 3 days will be considered a continued-stay and a new 5 -Day PPS MDS will not be completed. The existing Resident Classification will continue upon return.
- The SNF PPS Discharge Assessment requirement will not change.
- Activities of Daily Living (ADL) Scoring will be modified and Bed Mobility will be eliminated from the ADL Calculation.
- The below grid depicts the Proposed MDS Assessment, ARD and Payment Days:
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