MDS 3.0 October 2010
CRI is hosting a free webinar to outline the impending changes to MDS 3.0 RUG IV on June 24th at 1:00. To participate, please contact Kim Saylor at kims@conceptrehab.com.
This October, CMS will implement new rules that will significantly impact rehabilitation services in skilled nursing facilities. These changes will have dramatic impacts on contract therapy providers and in-house therapy programs.
Changes that the SNF interdisciplinary teams will need to make include:
Methods of determining projected therapy needs on the MDS
Strategies to optimize reimbursement without the use of hospital look back days, Section T or OMRA days
Staffing and delivery models to assure compliance with CMS changes regarding concurrent therapy
Concept Rehab is ahead of the changes and has distinct strategies to share with our customers to assure service delivery and compliance remain unprecedented, without sacrificing facility reimbursement.
Our long-standing focus on individualized 1:1 care has afforded us to be in a proactive versus reactionary position for the impending changes.
CRI can support your facility to make a successful transition to RUG IV and MDS 3.0!
Action on Physician Fee Schedule Delayed
Physician Fee Schedule
Although the House finally gave its approval to a 19-month extension of the physician fee schedule “doc fix” on 5/28/10, the Senate adjourned for its Memorial Day recess and will not take up the bill until the week of June 7. The House-passed bill would repeal the RUG-IV delay that was included in the health care reform law, but the final version of the bill jettisoned the extension of additional FMAP funding. Other changes could still be made to the legislation before it is cleared to be sent to the White House for the president’s signature.
With this legislative setback, the physician fee schedule will be cut 21 percent effective June 1. However, CMS has announced that it will hold claims for the first ten business days of June, which would carry through June 15.
Medicare Part B Therapy Caps Exception Process
Medicare Part B Therapy Caps
We are pleased to announce that the President has signed a Jobs-related bill, reinstituing the Therapy Cap Exception Process. This legislation is a short term measure which reinstitutes the Therapy Cap Exception Process, retroactively from January 31, 2010 until March 31, 2010.
RAC Overview
Recovery Audit Contractors (RAC) are CMS’ effort to identify improper Medicare payments, fight fraud, waste and abuse in the Medicare program and designed to guard the Medicare Trust Fund. In the Tax Relief and Health Care Act of 2006, Congress required a permanent and national RAC program to implemented. The RACs are scheduled to be phased in at different intervals across the nation; all states will be under the RAC system by 1/1/2010. Regionally, the following dates are applicable:
- Michigan started March 1, 2009
- Ohio, Kentucky and Pennsylvania started August 1, 2009
The RAC will focus on the four main categories found to be mostly responsible for improper payments in the Demonstration RAC:
- Lack of Medical Necessity
- Incorrect Payment Amounts
- Duplicate/ Medically Unlikely Services
- Admissions denied for lack of prior 3-day hospital stay
The RAC audits are not in place of any other current auditing systems. The number of claims a RAC can review is limited to 10% of the average monthly Medicare claims per 45 days (max of 200). The RAC look back period is limited to three years and cannot exceed October 1, 2007...
CRI’s Suggestions for RAC Preparation
Good record keeping and audit tracking
Appeal denials if you believe them to be unjust
Identify key persons and process for appeals
- Meet deadlines
- Send all appropriate information with the record
- Clear, legible copies
Assure all medical and treatment diagnoses are included on the UB-04
Timely physician signatures and dates on certification and re-certifications for skilled stays
Don’t underestimate impact of therapy documentation
- Prior Level of Function (PLOF) must be clearly identified
- Don’t treat for goals beyond the PLOF
- Assure objective and measurable progress is documented
- Must identify ongoing need for therapy services
Therapy and Nursing Documentation must coordinate
- Identify need for skilled intervention
- Identify response to therapy services
- Functional levels should match in nursing and therapy documentation or identify specific reasons for differences
Don’t Panic: Long Term Care providers are the masters of adaptation
ICD-10 Code Sets Proposed
On 8/21/2008, The U.S. Department of Health and Human Services (HHS) proposed new code sets to be used for reporting diagnoses and procedures on health care transactions. Under the proposal, the ICD-9-CM code sets would be replaced with the ICD-10 code sets, effective October 1, 2011. Adoption of the ICD-10 code sets is expected to:
- Support value-based purchasing by accurately defining services and providing specific diagnosis and treatment information, such as identifying cases of MRSA and other specific conditions, and would further Medicare’s ability to detect and prevent program abuse.
- Support comprehensive reporting of quality data.
- Allow the United States to compare its data with international data to track the incidence and spread of disease and treatment outcomes because the United States is one of the few developed countries not using ICD-10.
- Ensure more accurate payments for new procedures, fewer rejected claims, improved disease management, and harmonization of disease monitoring.