Demonstrating the Value of SLP Services in the New SNF Payment Model

Know Your Value!

On October 1, 2019, skilled nursing facilities (SNFs) will implement the patient-driven payment model (PDPM) for Medicare reimbursement, which bases payment for patients with speech-language pathology needs on their clinical characteristics. Here are some ways speech-language pathologists (SLPs) can demonstrate their value in this new payment model.

Success under PDPM will require SLPs to assist in the identification of patient needs.

SLPs play a critical role in identifying patients for treatment and determining their plan of care. Comprehensive coding that recognizes all diagnoses and comorbidities/complexities is critical.  

Payment under PDPM will require SLPs to help SNFs maintain high-quality.

Therapists play an imperative part in quality improvement and avoiding payment adjustments under the value-based purchasing program (VBP), the quality reporting program (QRP), and Nursing Home Compare.

Involve SLPs in the completion of the Minimum Data Set (MDS)

Engaging SLPs in the completion of relevant sections of the minimum data set (MDS) ensures accuracy of the data, helps identify patients who need speech-language pathology services, and facilitates interprofessional practice. SLPs can contribute to this process either directly or in consultation with the MDS coordinator.  

  • Section K: Swallowing and Nutritional Status
    • K0100A Loss of liquids/solids from mouth when eating or drinking
    • K0100B Holding food in mouth/cheeks or residual food in mouth after meals
    • K0100C Coughing or choking during meals or when swallowing medications
    • K0100D Complaints of difficulty or pain with swallowing
    • K0100Z None of the above
    • K0510C2 Mechanically Altered Diet While a Resident
  • Sections B & C: Cognition 
    • BIMS
      • C0200 Repetition of three words
      • C0300 Temporal orientation
      • C0400 Recall
    • CFS
      • B0100 Coma and completely dependent or ADL did not occur
      • C1000 Severely impaired cognitive skills (C1000 = 3)
      • B0700, C0700, C1000
        • Two or more of the following:
          • B0700 >0 Problem being understood;
          • C0700 =1 STM problem;
          • C1000>0 Cognitive skills problem; and
        • One or more of the following:
          • B0700 >=2 severe problem being understood;
          • C1000 >=2 severe cognitive skills problem
  • Sections I & O: Clinical Category
    • I4300 Aphasia
    • I4500 CVA, TIA, Stroke
    • I4900 Hemiplegia or Hemiparesis 
    • I5500 Traumatic Brain Injury 
    • I8000 Laryngeal Cancer
    • I8000 Apraxia 
    • I8000 Dysphagia
    • I8000 ALS
    • I8000 Oral Cancers
    • I8000 Speech & Language Deficits
    • O0100E2 Tracheostomy Care While a Resident
    • O0100F2 Ventilator or Respirator While a Resident

SLPs help prevent Medicare audits by ensuring claims and documentation are complete and accurate. SLPs play a valuable role in managing:

  • Changes in payment that result from changes in the coding or classification of SNF patients versus actual changes in case mix.
  • Changes in the volume and intensity of therapy services provided to SNF residents under PDPM compared to resource utilization group (RUG) IV.
  • Compliance with the group and concurrent therapy limit.
  • Any increases in the use of mechanically altered diet among the SNF population that may suggest that beneficiaries are being prescribed such a diet based on facility financial considerations rather than a clinical need.
  • Any potential consequences (e.g., overutilization) of using cognitive impairment as a payment classifier in the speech-language pathology component.
  • Facilities whose beneficiaries experience inappropriate early discharge or provision of fewer services (e.g., underutilization due to the variable per-diem adjustment).
  • Stroke and trauma patients, as well as those with chronic conditions, to identify any adverse trends from application of the variable per-diem adjustment.
  • Use of the interrupted-stay policy to identify SNFs whose residents experience frequent readmission, particularly facilities where the readmissions occur just outside the 3-day window used as part of the interrupted-stay policy.
  • Changes in quality reporting performance and star ratings that could indicate a decline in quality or patient satisfaction.

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