Real Time Memo July :: Reliant Rehab

Real Time Memo July

FY2019 SNF Final Rule Released
PDPM Replaces RUGs IV On October 1, 2019

CMS released the SNF FY2019 (effective October 1, 2018) final rule on July 31, 2018. The final rule includes annual payment update provisions, SNF QRP updates, and finalizes the Patient Driven Payment Model (PDPM) implementation date as October 1, 2019.

Market Basket Update

  • Finalized FY2019 market basket increase at 2.4%, equating to $820 million increase in Medicare payments to SNFs.

Patient Driven Payment Model (PDPM)

  • Finalized with few modifications.
  • Effective date is FY2020: October 1, 2019.
  • No transition period from RUG-IV to PDPM. Providers will bill under current RUG-IV model through September 30, 2019. There will be no concurrent billing of the two models; therefore, all residents whose stay meets skilled level of care will be billed under PDPM requirements beginning October 1, 2019.
  • The 25% limit on group and concurrent therapy is combined.
  • Case Mix Components:
  • SLP component without modification
  • PT and OT components with minor change to Function Score calculation (reflective of Section GG 2018 updates) 
  • Nursing component with minor changes to Function Score calculation (reflective of Section GG 2018 updates)
  • Non-Therapy Ancillary component without modification
  • Variable per diem adjustments remain without modification (i.e. 2% reduction per week for PT and OT case mix).
  • Discharge Assessment confirmed without modification. Requirement to complete Section O, documenting therapy minutes remains.
  • Surgical procedure coding on Admission Assessment modified to identify a surgical procedure category which occurred during preceding hospital stay within item J2000. Item set to be created by CMS. Surgical coding will not be required within I8000.
  •  Revised the Interim Payment Assessment (IPA) as optional instead of required. 

SNF Quality Reporting Program

  •  No new measures added to program. CMS indicates all measures adopted in the SNF QRP meet IMPACT ACT of 2014 requirements.
  • Failure to submit appropriate data on at least 80% of MDS claims will receive 2.0% reduction in payment. Meaning non-compliant SNFs will receive 0.4% increase for FY2019.
  • Finalized Meaningful Measures Initiative factor of “The costs associated with a measure outweigh the benefit of its continued use in the program.” CMS will consider costs to providers when evaluating quality measures included in program.

SNF Quality Reporting Program

  •  No new measures added to program. CMS indicates all measures adopted in the SNF QRP meet IMPACT ACT of 2014 requirements.
  • Failure to submit appropriate data on at least 80% of MDS claims will receive 2.0% reduction in payment. Meaning non-compliant SNFs will receive 0.4% increase for FY2019.
  • Finalized Meaningful Measures Initiative factor of “The costs associated with a measure outweigh the benefit of its continued use in the program.” CMS will consider costs to providers when evaluating quality measures included in program.

SNF Value-Based Purchasing (VBP) Program

  • Based on performance on the SNF VBP all cause 30-day hospital readmissions measure, SNF’s will receive either a positive or negative payment update.

CMS Open Door Forum Scheduled for August 2, 2018

  • Start time: 2 p.m. E.T.
  • Dial in: 1-800-857-1738; Passcode: 7785347
  • Agenda includes
  • FY2019 SNF PPS Final Rule
  • Payroll-Based Journal Submission Reminder
  • Long-Stay Hospitalization Measure- Nursing Home Compare

Reliant Rehabilitation is ready to embrace our industry’s future as a partner with you. Our planning and preparation for PDPM ensures continued quality of care and successful outcomes for your residents without interruption as we cross the threshold of this new model.

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