Wednesday, July 8, 2015

OIG Issues Report on Impact of New SNF PPS Therapy Assessments

Dan Ciolek and Dianne De La Mare

Last week the Department of Health and Human Services (HHS) Office of Inspector General (OIG) released a report titled Skilled Nursing Facility Billing for Changes in Therapy: Improvements Are Needed. The purpose of the study was to examine the Centers for Medicare and Medicaid Services (CMS) introduction of three new SNF PPS assessments in fiscal years 2011 and 2012 to capture changes in a beneficiary’s therapy services. These new assessments address: 1) start-of-therapy, 2) end-of-therapy, and 3) change-of-therapy (decreases or increases in therapy services), during a beneficiary’s Part A stay. The OIG report provides information about SNF billing for changes in therapy under these new policies, as well as the extent to which SNFs used the new assessments incorrectly.

The OIG report presented several findings including:

· SNF billing for change-of-therapy from 2010-20013 increased slightly form 27-31 percent.

· When SNFs are permitted the flexibility to choose between a scheduled assessment, and a combined change of therapy assessment when a beneficiary’s therapy level changes, SNFs use assessments differently when decreasing therapy than when increasing therapy.

· From 2011-2013, there was an improvement in the incorrect use of the new therapy assessments, but start-of-therapy assessments continue to be used incorrectly at a rate of 27 percent.

The OIG report included two specific recommendations for CMS:

1. Reduce the financial incentives for SNFs to use assessments differently when decreasing therapy than when increasing therapy.

2. Strengthen the oversight of SNF billing for changes in therapy.

CMS concurred with the OIG recommendations, but acknowledged that CMS has “…worked to balance the need to provide accurate payment for therapy services with the burden that reporting requirements place on providers.” CMS also noted that they currently are conducting the SNF PPS Payment Model Research Project to guide future reforms, and will continue to monitor SNF billing patterns for changes in therapy to target providers for education and claims review.

AHCA is reviewing this OIG report and will be following-up with CMS to provide comments and recommendations.

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