Payroll-Based Journal (PBJ) data submitted to the Centers for Medicare & Medicaid Services (CMS) in accordance with the agency’s requirement that went into effect July 1, 2017, is now live on Nursing Home Compare and is being used to calculate the staffing rating in the Nursing Home Five-Star Quality Rating System. Beginning June 1, 2018, CMS will no longer collect facility staffing data through the CMS-671 form, meaning that providers will no longer have to fill out page 2 of this form.
On Friday, April 27, 2018, the Centers for Medicare & Medicaid Services (CMS) published a highly anticipated proposed rule containing a recommendation to replace the existing case-mix classification methodology, the Resource Utilization Groups, Version IV (RUG-IV). The proposed model, Patient-Driven Payment Model (PDPM), significantly revises the Resident Classification System, Version I (RCS-I), which was introduced as a potential RUG-IV replacement last April in an Advanced Notice of Proposed Rulemaking.
Many concerns and questions from stakeholders followed the introduction of the Resident Classification System (RCS), a proposed replacement for the Prospective Payment System’s RUG-IV model published in an Advanced Notice of Proposed Rule-Making (ANPRM) last April. Highly anticipated ever since, the Centers for Medicare & Medicaid Services (CMS) released a proposed rule late Friday, announcing significant revisions to the RCS model. The result? The Patient-Driven Payment Model (PDPM).
The Billers’ Association is seeking long-term care managers, revenue cycle enthusiasts, and billing professionals to join our growing ad-hoc list of experts interested in contributing to articles in our monthly publication, Billing Alert for Long-Term Care. This digital newsletter provides expansive regulatory coverage, including MDS changes, reimbursement issues, and expert advice and analysis to help improve job performance in all aspects of the revenue cycle management system.
Q: I have heard that the transition to the Resident Classification System, version 1 (RCS-1) will probably be introduced the same way the prospective payment system (PPS) was (with RCS-1 being introduced in increments over a four-year period). Is this correct, and if CMS chooses this route, will the PPS schedule need to be maintained for the next three CMS fiscal years?
A: There is some talk about a phase-in system, in which case, yes; the PPS schedule would be maintained for the next three fiscal years. I foresee a transition from the minimum data set (MDS) v1.15 to MDS v1.16, with all existing covered residents requiring a new MDS on October 1, 2018. The final rule on RCS-1 will have more details when it is released.
On January 3, 2018, MedPAC commented on CMS’ proposed rule for Medicare Part C and Medicare Part D. The proposed rule includes provisions that would revise regulations for both the Medicare Advantage program (Part C) and the Prescription Drug Benefit program (Part D).
Skilled nursing facility (SNF) providers are on the edge of their seats as they anticipate the Centers for Medicare & Medicaid Services' (CMS) consideration of a replacement for the Resource Utilization Group (RUG) system, which will change the way facilities are reimbursed for SNF Medicare Part A residents beginning FY2019. The Resident Classification System, Version 1 (RCS-1) will be the most significant change in the current reimbursement model, which has been in place for nearly two decades. Since being published in the Federal Register on April 27, 2017, providers and advocacy groups have submitted public comments and recommendations on the SNF prospective payment system (PPS) payment methodology proposed in the Summary of Advance Notice. Many concerns have been raised, especially regarding the reimbursement methodology for therapy services.
Every spring, CMS makes available the Program for Evaluating Payment Patterns Electronic Report (PEPPER) for SNFs. The agency offers variant reports for a number of other Part A provider types, including hospitals, home health agencies, and hospices. These tools, which provide comparative billing data across a handful of setting-specific risk areas, can play an important part in a provider’s corporate compliance program. To get the most out of the report, SNFs should have a strategy in place for integrating its findings into their corporate compliance program before accessing this year’s edition.
By definition, Medicare coverage is considered skilled, which is a higher level of care than required by most facility residents. Because of early hospital discharges, residents often require heavy care when they are admitted to the long-term care facility. Residents are assessed within five to eight days of admission with the Minimum Data Set (MDS). Medicare assessments are repeated on the 14th, 30th, 60th, and 90th days.
Last month, the Department of Justice and CMS announced a $125 million settlement with RehabCare, a subsidiary of Kindred Healthcare, over improper Medicare billing. Allegations leveled at RehabCare ran the gamut of pecuniary faults: setting unrealistic financial goals for therapists, denying discontinuation of patients’ services after therapists recommended discharge, over-treating, and upcoding.