The Centers for Medicare & Medicaid
Services (CMS) has released proposed regulations for skilled nursing facilities
(SNFs) to be effective October 1, 2014. The proposal included an announcement
that two consulting firms were contracted to identify potential alternatives to
the existing methodology used to pay for therapy services received by Part A
residents. The report
recommends further investigation into two models: a resident characteristic
model, which bases payment on medical, functional, and cognitive status, and a
model that is similar to the current prospective payment model.
proposed regulations, CMS referred to a recently released report
regarding two utilization trends.
- Over the past 3 years, the
percentage of residents classified into Ultra-High Rehabilitation Utilization
Groups (RUGs) has increased greatly, to 50% of billed service days (Ultra-High
is at least 720 therapy minutes per week).
- The amount of therapy
rendered in each rehabilitation group, in particular the two highest therapy
RUG classifications, is often just enough to qualify for that group. This
finding is consistent with some ASHA member reports that managers interpret RUG
minimum therapy minutes as maximum minutes.
The proposed rule
provides for a 2% inflationary update and aligns electronic health record
incentives and payment adjustments across the care continuum.
Since 1998, the SNF prospective payment system has been
in place for Part A residents. Therapy minutes per week have been the basis for
determining the Medicare per diem payment in combination with the Minimum Data
Set (MDS) comprehensive initial assessment. There are five RUG levels, ranging
from 45 to 720 therapy minutes, and additional levels that define "extensive"
non-rehabilitation needs. CMS has refined this payment system several times in
recent years, but in this proposed rule acknowledges that a major change in the
methodology is needed.
information, please see ASHA's Medicare
Guidance for SLP Services in Skilled Nursing Facilities (SNFs). For
questions, please contact [email protected].