Harmony Healthcare Blog

Resident Classification System (RCS-I): Top 14 Points (Part 1)

Posted by The Harmony Team on Thu, May 04, 2017

Edited by Kris Mastrangelo


Compliance • Audits/Analysis • Reimbursement/Regulatory • Education/Efficiency

changes ahead.jpgCMS (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).   

  1. Transition from Resource Utilization Groups (RUG-IV) to Resident Classification System (RCS-1). 
  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)
  1. The PT/OT and SLP components will be determined based on Resident Characteristics, not Therapy Days and Minutes.
Advanced Notice of Proposed Rulemaking
  1. Nursing Classification will align with Current Nursing RUG Levels
  1. MDS Diagnosis Coding Accuracy is critical. 
  1. Proposed System will base reimbursement on the 5-Day MDS Assessment Only and all other PPS assessments eliminated
  1. Reclassification for a Significant Change in Status will occur with completion of a Significant Change in Status Assessment. 
  1. The Resident Classification covers the entire Medicare stay unless a Significant Change in Status Assessment is performed. 
  1. Reimbursement rate will be adjusted throughout the Medicare Covered Stay with decreasing rate accounting for utilization of fewer resources as the stay extends. 
  1. A patient re-hospitalized for greater than 3 days will have a new 5-Day MDS Assessment completed to reclassify. 
  1. 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. 
  1. The SNF PPS Discharge Assessment requirement will not change
  1. Activities of Daily Living (ADL) Scoring will be modified and Bed Mobility will be eliminated from the ADL Calculation. 
  1. The below grid depicts the Proposed MDS Assessment, ARD and Payment Days:
anprm.pngTo download a copy of the Advanced Notice of Proposed Rulemaking, click here.  Harmony Healthcare International (HHI) is available to assist with any questions or concerns that you may have regarding regulatory changes.  You can contact us by clicking here.  Looking to train your staff?  Join us in person at one of our our upcoming Competency/Certification Courses.  Click here to see the dates and locations.


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Tags: proposed rule

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