Thursday, December 2, 2010

Guest Post: Paybacks To CMS Loom As Providers Adjust To MDS 3.0

December 2, 2010
By: John Sheridan, President, eHealth Solutions

MDS coordinators are extremely busy now adapting to the demanding requirements of MDS 3.0. It’s a new way of doing business. The new resource utilization group (RUG) IV categories include new clinical rules and require better documentation and attention to the voice of the resident than did the predecessor MDS 2.0.

All of us in long term and post-acute care are working diligently to serve residents, improve compliance, and identify and treat resident and patient needs. Now that the implementation date has come and gone, there are new challenges facing nursing facility providers. Looming on the horizon are possible “take backs” of any RUG-IV payments made to providers versus the RUG-53 hybrid grouper. The Centers for Medicare & Medicaid Services (CMS) is required to use the grouper to calculate payments, but it has not yet implemented. In case you haven’t yet heard, Congress delayed the implementation of RUG-IV until Oct. 1, 2011—one year later than the agency had initially planned for.

As CMS develops the RUG-53 hybrid payment process, the fiscal year 2011 payments are being paid with a budget-neutral RUG-IV system. In the meantime, nursing home advocates are lobbying to get Congress to move the implementation back to Oct. 1, 2010, which will serve to avert the mess of sorting out payments under hybrid-53 process.

If RUG-IV implementation is not rolled back, CMS will be required to recapture some reimbursement monies made to facilities under the hybrid-53 grouper but corrected under the RUG-IV. Those who are not prepared to measure and manage therapy may face this. Providers who prepare now by reducing concurrent therapy and boosting group and individual therapy will be less likely to get a “take back” notice.

If you want to avoid or reduce the possibility of returning monies to CMS, make time to forecast therapy minutes based on your history of Medicare days by rehab level and plan for an increase of individual therapy. This may mean adding more therapists to the payroll. Calculating these minutes is a fairly easy task and is explained in this month’s Provider magazine, page 49. There you will find out how to make these calculations and compare reimbursements under each of the RUG payment processes.

No comments:

Post a Comment