Harmony Healthcare Blog

SNF PPS Final Rule FY19: Top 10 Things You Need to Know

Posted by Kris Mastrangelo, OTR/L, LNHA, MBA on Thu, Aug 02, 2018

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Edited by Kris Mastrangelo


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

Change Just Ahead - Green Billboard on the Rising Sun Background.The SNF PPS Final Rule was released 7.31.18.  The Top 10 things you need to know:  

  1. There is a 2.4% Medicare Part A Rate increase effective October 1, 2018 (Fiscal Year 2019). This equates to 820 Million dollars for the SNF industry.                                                                                      
  1. Patient Driven Payment Model (PDPM) is the SNF Payment System that correlates payment to the patients’ conditions and care needs rather than volume of services (Cost Based) provided or resources rendered (PPS RUGs System).

    PDPM is effective October 1, 2019 (Fiscal Year 2020).  The PDPM applies to Medicare Fee for Service (FFS) only patients and does not apply to Medicare Advantage (yet).

    Per CMS

    “The PDPM is designed to improve the incentives to treat the needs of the whole patient, instead of focusing on the volume of services the patient receives, which requires substantial paperwork to track over time. Under the new SNF PPS case-mix model, patients will have that offers services tailored to their more opportunity to choose a skilled nursing facility condition and preferences, as the payment to nursing homes will be more based on the patient’s condition rather than the specific services provided by each skilled nursing facility.”
  1. One component of the Patient Driven Payment Model (PDPM) is the tapering of payment the longer the patient stays. It is common practice for therapists to develop patient specific transitions of care. These mechanisms are not new but may have been overlooked under the current payment system. 
  1. The PDPM is a Per Diem Payment and will not increase or decrease the total dollars allocated to this sector, hence, it is budget-neutral.
  2. The Patient-Driven Payment Model (PDPM) has 6 Components that comprise the per diem rate.
    • Physical Therapy (PT) Component Per Diem Rate
    • Occupational Therapy (OT) Component Per Diem Rate
    • Speech Pathology (SLP) Component Per Diem Rate
    • Non-Therapy Ancillary Services (NTAS) Component Per Diem Rate
    • Nursing Component Per Diem Rate
    • Non-Case Mix Component Per Diem Rate
  3. The Patient-Driven Payment Model (PDPM) allows for up to 25% Groups and Concurrent Therapy. CMS is reconsidering these subjective limits and may address in a future rule.  If the MDS depicts a greater than 25% delivery, the provider will receive a non-fatal alert. 
  4. Value Based Purchasing (VBP) is in play and in effect October 1, 2018! The timelines are tricky. Note the changes in Calendar Year (CY) and Fiscal Year (FY). 
    • Year 1
      • Baseline Year: CY2015
      • Performance Year: CY 2017
      • Financial Impact 2019 
    • Year 2
      • Baseline Year: FY 2016
      • Performance Year: FY 2018
      • Financial Impact FY 2020                                           
    • Year 3
      • Baseline Year: FY 2017
      • Performance Year: FY 2019
      • Financial Impact FY 2021
  5. Value Based Purchasing (VBP) Measure is 30-Day All-Cause Readmission Measure (SNFRM). This measure may change to potentially preventable admissions in 2021.

    (Year 1) Better of achievement or improvement score. 
  • Achievement Score
    If SNFRM rate < 16.4%, then achievement score is 100
    If SNFRM rate > 20.4%, then achievement score is 0 
  • Improvement Score
    If SNFRM rate < 16.4%, then improvement score is 90
    If SNF RM CY2017 rate > CY2015 rate, then improvement score is 0

     (Year 2) Better of achievement or improvement score. 
  • Achievement Score
    If SNFRM rate < 16.3%, then achievement score is 100
    If SNFRM rate > 19.8%, then achievement score is 0 
  • Improvement Score
    If SNFRM rate < 16.3%, then improvement score is 90
    If SNF RM CY2017 rate > CY2015 rate, then improvement score is 0
  • Facility specific scores can be obtained from the SNF RM QIES Report. 
Free RUG Analysis - Compare your facility's utilization with current national CMS data
  1. Quality Reporting Program (QRP) Public Display of the functional outcomes measure in 2020. 
  • Effective October 1, 2018, failure to submit data results in a reduction of 2 percent points. 
  • MDS-Based Measures expand October 1, 2018 to include: 
    • Skin Integrity
    • Falls
    • Function
    • Drug Regimen Review 
  1. SNF QRP Contact Methods to correspond include QIES ASAP System, US Postal Service and Email to: 
  • Notify a SNF of non-compliance with the SNF QRP requirements for a program year and
  • Notify SNF’s of the CMS final decision regarding any reconsideration requests.

The Harmony Healthcare International (HHI) site visit process is an intensive, detailed review of the medical record content to identify compliance risk areas, revenue and coding opportunities, systematic refinements with the overarching goal to improve medical record accuracy and minimize compliance concerns. 

To learn more about our site visit process, click here.

Harmony Healthcare International (HHI) is available to assist with any questions or concerns that you may have.  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: Final Rule

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