What should you be doing? 2012 SNF PPS

From the desk of Harmony Healthcare’s CEO Kris Mastrangelo:
SNF 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.

CMS has posted a transition document for implementation of changes scheduled for October 1, 2011. To access this document follow the link below: http://www.cms.gov/snfpps/03_RUGIVedu12.asp

To read the full article, please visit Harmony Healthcare’s website.


Please contact us today to find out how we can help your facility through the October 1st changes!

Therapy Center partners with nursing homes to deliver high quality, cost-effective rehabilitation services. Our services are designed to provide our partner facilities with the highest standard of patient care, increased revenues, reduced responsibility, elimination of staffing problems and ease of compliance. Unlike staffing agencies, Therapy Center welcomes the responsibility of operating and managing a profit-generating rehabilitation department for our partner facilities. We provide highly skilled therapists and a full spectrum of rehabilitation services including physical therapy, occupational therapy, speech therapy and more. Our goal is to enhance clinical outcomes while maximizing financial reimbursements for our partner facilities.

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Kristi Fredieu

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