Final 2014 SNF Rule
The same day CMS issued the final IRF rule, they issued the SNF Medicare Prospective Payment System update for the fiscal year 2014. In large part the final rule was in line with our expectations and close to the proposed rule issued earlier this year. The final rule includes a 1.3 percent Market Basket Increase for SNF Medicare payments beginning October 1 as well as several regulatory changes including the reporting of discreet therapy days on the MDS and the requirement to report therapy co-treatment minutes on the MDS.
Regrettably, CMS ignored much of the stakeholder comments and will require new reporting through item O0420 to the MDS 3.0 to capture distinct therapy days provided by all the rehabilitation disciplines to a beneficiary over the seven-day look-back period. CMS asserts that there was no change in policy, rather this is merely adding an item to the MDS to enable the agency to implement and track existing policy.
At RehabCare, we have been tracking distinct calendar days for therapy as part of our protocol for a long time, and ensuring the needs of our patients are met remains our primary objective. Continued compliance will require close attention to detail in order to ensure that patients remain in the appropriate RUG that accurately best represents their medical and rehabilitative needs rather than changing based solely on an arbitrary day count and a rolling 7-day calendar.
The SNF final rule also includes the requirement to report co-treatment minutes provided by therapy.
Co-treatment minutes are currently captured and reported on the MDS but not as a separate item. Co-treatment is a technique where two therapists from two different disciplines both treat the patient at the same time.
RehabCare currently records this treatment as part of documentation in the medical record. Reporting of this as a new item on the MDS is expected to be managed through our software vendors. CMS is expected to release specifications in the MDS 3.0 RAI manual.
We are working with our technology and software partners to ensure that we have the best tools and programs in place prior to October 1, 2013 to enable our therapists and customers to easily and appropriately implement the new requirements.