October 1, 2019 is officially here and over these last few weeks, SNFs and MDS Coordinators have been busy making final preparations to make this monumental transition to an entirely new payment model, PDPM. There is an enormous amount of work that needs to be completed by the SNF in order to successfully navigate all of the requirements that PDPM brings forth. Missing any of these critical elements can amount to lost revenue and negative payment implications. Follow the guide below and share with your interdisciplinary team in order to ensure a seamless transition to PDPM:
Tying up loose ends with RUG-IV
Just because it’s October 1st, it doesn’t mean we are completely in the clear yet. All Medicare A residents who resided in the SNF on or before September 30 are required to have a RUG-IV PPS assessment to cover all payment dates in September. Even residents who admit late in September need to have a 5-day ARD on or before 9/30/19. The assessment completion and submission requirements have not changed.
Managing managed care
All skilled managed care patients will need to have confirmation from each insurance company on how that particular plan is going to be paying the SNF starting on October 1, 2019. We have heard many plans are adopting PDPM as of October 1, 2019 but be aware that some plans can still pay based on RUG-IV. If a plan is following PDPM, that resident needs to be managed in the same manner as a traditional Medicare A patient.
Transitional IPA assessments
All Medicare A residents will need to have a mandatory IPA assessment planned with an ARD between October 1 and October 7, 2019. IPA assessments are unable to be combined with OBRA or PPS assessments and must be completed within 14 days of the ARD. In order to fully complete this IPA assessment, information will need to be gathered by the interdisciplinary team within a certain timeframe:
ARD set between October 1 - 17
Validate the primary reason for skilled stay diagnosis, which will be entered in I0020B. Ensure this maps to a clinical category and is not a “return to provider” code.
Complete the BIMS interview during the 7-day look-back period from the ARD.
Complete the PHQ-9 interview during the 7-day look-back period from the ARD.
Gather GG information during the 3-day look-back period from the ARD. Once data is gathered, the interdisciplinary team determines “usual functioning”.
Monitor for signs and symptoms of a swallowing disorder and use of mechanically altered diet during the 7-day look-back period from the ARD.
Complete the IPA MDS within 14 days from the ARD.
Submit the IPA MDS within 14 days from the completion date
Changing dynamics of clinical discussions
Be prepared and have a process in place to start having daily clinical discussions surrounding clinical elements that might render an IPA assessment beneficial. Some of these conditions include:
A clinical change resulting in the need to change the primary diagnosis for the skilled stay
Resident returns from the hospital following an interrupted stay
The addition of active diagnoses that could potentially result in a change in Nursing or NTA category
The addition of new treatment regimens or extensive services that could result in a change in the Nursing or NTA category (Ex: oxygen, breathing treatments, IV antibiotics, IV fluids, etc.)
A change in the resident’s cognitive function (BIMS score of 12 or less)
A change in the resident’s PHQ-9 mood interview score (10 or more)
The trialing of or new order for a mechanically altered diet
The implementation of two or more restorative nursing programs 6 days a week
Patient having documented symptoms including but not limited to SOB while lying flat, fever, weight loss, and signs and symptoms of a possible swallowing disorder
Significant changes with GG functioning
If your facility is struggling with this concept, please reach out to Concept Rehab for a demonstration of our "Outcomes Optimizer" tool that helps to meet these objectives.
Many MDS coordinators, like myself, thrive on having lists, forms, tools, and systematic approaches to stay organized; especially during times that may be considered chaotic. I can’t imagine anything that would quite “top” the current PDPM transition we are in the trenches with now. Click the link below to download a “PDPM Transition Log” to help make sure these critical elements are not missed during this transition.
And lastly, take a moment this week to appreciate all of the hard work, training, and education efforts your facility staff has endured over this past year to prepare for this monumental week of change.