4/15/2018

1

Disclosure of Commercial InterestsI have commercial interests in the following organization(s):

• Celtic Consulting, LLC• President• Celtic Consulting is a nationally recognized long-term care advisory firm, focused on

providing one-on-one oversight, to facilities of all sizes.

Medicare Changes for the Administrator: How Quality, Value and a New Payment System Impact Your Bottom Line

Presented By:Maureen McCarthy, RN, BS, RAC-MT, QCP-MT

President of Celtic Consulting

Maureen McCarthy RN, BS, RAC-MT, QCP-MT

Maureen is the President of Celtic Consulting, LLC and the CEO and Founder of Care Transitions, LLP. She has been a registered nurse for 30 years with experience as an MDS Coordinator, Director of Nursing, Rehab Director and a Medicare biller. McCarthy is a recognized leader and expert in clinical reimbursement in the skilled nursing facility environment. She is dually certified in both the resident assessment process and QAPI by nationally recognized organizations and holds Master Teacher status in both and is a board member of American Association of Post-Acute Nurses (AAPACN) and is an Expert Advisory Panel member for American Association of Nurse Assessment Coordination (AANAC).

Maureen and her associates at Celtic Consulting regularly provide the following services for SNFs, state affiliates and provider organizations:

• 5 Star Quality Improvement Program• Quality Auditing• Clinical Care Management• RCS/PPS/MDS/CMI Services • Compliance Solutions• Medicare Compliance Auditing• Customized Education / In-Services

4/15/2018

2

Objectives• Explain Medicare’s Value Based Purchasing (VBP) and how

to program is funded and monitored.• Understand the three new Quality Measures being

collected now for 2018 use.• Differentiate between 5-Star and Quality Reporting (SNF

QRP).• Prepare for the shift to a condition based payment system.

SNF Quality Reporting ProgramSection GG Updates 2017What you should be doing now!

Improving Medicare PAC Transformation Act of 2014

• This Act is more detailed than Triple Aim and calls for:– Data element uniformity (standardized assessment and data)– Quality care and improved outcomes– Comparison of data across continuum– Improved discharge planning– Exchangeability of data– Coordinated care

• Phased in over 5 years through 2020• CMS is required to report data within 2 years of inception

of the measures

4/15/2018

3

SNF QRP

IMPACT Act

Improve Outcomes

Improve Care

Coordinati-on

Allow Comparis

onsResearch

Improve DC

Planning

QMs for SNFQRP under IMPACT • MDS-Based Measures:

– Functional status and cognition changes from admit to d/c (10-1-16)

– Skin integrity and changes: new or worsening pressure ulcers (10-1-16)

– Falls with major injury (10-1-16)– Care Plan- communication of health info (10-1-19)– Medication reconciliation (10-1-18)– GG goals met/ Admission-to-Discharge Performance

improvement (10-1-18)• FY17 Claims-Based Measures 2017• MSPB-Medicare Spending per Beneficiary• Discharge to community, • Potentially Preventable re-hospitalization

SNF QRP QMs Newly IMPACTing Payment FY2019

Claims-Based Quality Measures

Medicare Spending per Beneficiary

(MSPB)

Discharge to Community

Potentially Preventable 30-

Day Post-DC Readmission

(PPR)

4/15/2018

4

SNF QRP Claims-Based Measures

Potentially Preventable Readmissions • Slight variation on the rehospitalization QM reported in

Five Star• Only Medicare Part A• Time period = 1st 30 days following Discharge from SNF

excluding day of Discharge • Measures readmission rates for those readmitted to a

hospital or LTCH who have a principal diagnosis considered to be unplanned & potentially preventable.

What’s Potentially Preventable?

• Respiratory: COPD, asthma, aspiration PNA, bacterial PNA, flu

• Cardiac: CHF, hypo/hypertension, some arrhythmias• Some diabetic complications• Skin/Subcutanous: pressure ulcers, infections• Septicemia• GI/GU: UTI, Cdiff, dehydration, gastroenteritis, acute

kidney failure, electrolyte imbalances, intestinal impaction

SNF QRP Discharge to Community• Slight variation on the DC to community QM reported in

Five Star• Only Medicare Part A• Time period = 31 days post discharge to community• Measures SNF rate of successful discharge through no

unplanned rehospitalizations nor death in the 31 days (includes day of discharge)

• Discharge status codes on the SNF claim are important here– Only these four codes are considered - O1, 02, 81, 86

(82-planned d/c Acute) – Does your team communicate with finance on this?

4/15/2018

5

SNF QRP Medicare Spending per Beneficiary (MSPB)

• Also claims-based, Part A only but includes spending for both A&B• CMS Goals for this measure include:

– Improve care coordination & efficiency of care– Facilitate comparisons while accounting for case mix – Create accountability amongst providers for quality & value by

measuring resource use for an entire “episode” of care• Calculates both Attributor Provider & other Provider services costs

throughout the episode which begins on admit & for 30 days after discharge

• Episodes are only compared to other episodes of like providers

SNF QRP Medicare Spending per Beneficiary (MSPB)

• Exclusions of Clinically unrelated services including:– Planned hospital admissions– Routine management of certain preexisting chronic conditions– Some routine screening and health care maintenance– Immune modulating medications

• Beneficiary must have been enrolled in Medicare Part A for the entire 90-day period prior to admission date for episode & for entire episode window (Part A stay through 30 days from discharge.)

• Will have risk-adjustments r/t prior care/services, age, clinical categories, etc.

MSPBMeasure calculated by comparing your SNFs Medicare spending to other providers nationally of the same type during the performance period.

If provider’s value is >1 = Medicare spending was higher than the national median spendingIf provider’s value is <1 = Medicare spending was lower than the national median spending

4/15/2018

6

MSPB Example

Claims-Based Reports

• Confidential Feedback Reports begin October 2017– Using claims for CY2016

• Public Reporting begins October 2018– Using claims for CY2017

4/15/2018

7

SNF QRP QMs Currently IMPACTing Payment

MDS-Based Quality Measures

New or Worsened Pressure

Ulcers

Falls with Major Injury

Adm & DC Functional

Assessment with Care Plan

SNF QRP Section GG RAI/MDS Coding• Primarily updated the RAI to include CMS clarifications • Responses to gateway questions for walking & WC use do not

have to be the same on both Admission and DC Performance.• DASHES: never dash a “Performance” column, only allowed in

“Goal” column as long as you’ve chosen at least one goal• Will be adding codes to MDS 10/1/18 to address coding GG

goals

SNF QRP MDS-Based Reporting

4/15/2018

8

4/15/2018

9

4/15/2018

10

Collecting Facility Data & Reports• Subsequent Review and Correct Reports:

• After the first quarter, subsequent reporting quarters data are added. • Cumulative data are displayed & 80% compliance is required for the entire reporting year.• When a new reporting year begins, the oldest quarter is dropped (i.e., rolling quarters).

• Calculations of compliance for assessments that straddle a reporting year will be counted toward the reporting year in which they occur:

– 5 Day & 14 Day PPS 12/2017 and DC MDS 1/5/18. If new/worsened pressure ulcer occurs in Jan. but not December, each will count in their respective reporting period

• CMS will not be providing details on QRP data. Providers will need to use existing available reports.

• Review & Correct Reports update Monday in early AM• Data calculated on 1st day of the month after quarter closes

4/15/2018

11

Model language for initial notification letters: “This letter is to officially notify you that (Facility Name, CMS Certification Number 000000) is subject to a reduction in payment for not meeting section IMPROVING MEDICARE POST-ACUTE CARE TRANSFORMATION ACT OF 2014 (IMPACT Act), Section 1888(e) of the Social Security Act (42 U.S.C. 1395yy(e))requirement for SNFs to submit quality data. Therefore, Medicare payments to your facility will be reduced by two (2) percentage points for [insert upcoming year]; unless you can provide evidence that this determination is in error. CMS updates the requirements and the quality reporting measures required for the SNF Quality Reporting Program (QRP) annually through rulemaking. CMS has determined that this SNF is subject to a 2% reduction in the FY (insert upcoming year) annual increase factor for failure to meet quality reporting requirements pursuant to the Impact Act Section 1888(e) because of the following reason(s): • The SNF failed to submit the required quality measures that are to be submitted to the CMS Quality Improvement Evaluation System (QIES) system.

If you believe you have been in compliance with the quality data reporting requirement and have been identified for this payment reduction in error, you must submit an email requesting reconsideration and provide documentation demonstrating your compliance. You have the right to request a reconsideration of this decision. If you choose to request a reconsideration of this decision, you must submit the request no later than 30 days following the receipt of this letter.

Tips for Managing QRP Compliance – Section GG• Strengthen facility documentation related to GG Functional

performance. Ensure “usual” performance determination is documented to account for fluctuations in the assessment period.

• Consider goals attainable by the End of PPS stay which often differs from the ultimate long term functional goal.

• Make Functional performance & goals a topic in weekly Medicare meetings.

• If you are only choosing 1 goal, start choosing at least 1 goal in each category (Self-Care & Mobility.)

• Track goals, gather data related to those met and those not met, analyze for possible PIPs.

Tips for Managing QRP Compliance

• Know how MDS completion affects QMs; comply with MDS timely completion & submission requirements.

• For claims-based measures, develop a process to ensure appropriate review of discharge status codes. How is this communicated?

• For DC & readmission QMs, develop/review processes to transition & coordinate care with other care settings.

• For MSPB, review claims process for accurate reporting of resource use.

• Strengthen clinical assessment and skills. Analyze events for improvement opportunities.

• Utilize available reports to review & correct, where applicable.

4/15/2018

12

Reports to Assist with QRP Auditing

• Validation Reports• SNF QRP Review & Correct• MDS Missing Assessment report• MDS Error Detail by Facility report• Assessments with Error Number XXXX report (use 3863

for GG goals.)• Admission/Reentry Report• MDS Discharges Report• Facility MDS software reports

SNF QRP Preview 10/1/18For FY2020

• Drug Regimen Review (medication reconciliation)

• Changes in Skin Integrity PAC: Pressure Ulcer/Injury

• Change in Self-Care Score for Medical Rehab Patients

• Change in Mobility Score for Medical Rehab Patients

• Discharge Self-Care Score for Medical Rehab Patients

• Discharge Mobility Score for Medical Rehab Patients

4/15/2018

13

MDS Updates: October 1, 2018

Prior Functioning in Everyday Activities:• Self Care• Indoor Mobility• Stairs• Functional Cognition

Prior Device Use including:• Lifts• Orthotics/Prosthetics

Expands Section GG Self-Care

Expands Section GG: Mobility

4/15/2018

14

Expands Section GG: Mobility

New GG Choices for Goals

And, don’t forget: Drug

Regimen Review

4/15/2018

15

Quality Measure TIP- Rehospitalization Focus

QRP

5 Star

VBP

SNF Value-Based PurchasingThe Next CMS Initiative

SNF Value Based Purchasing

• Part of Protecting Access to Medicare Act of 2014 (PAMA)• Program begins FY 2019 (10/1/18)• Concept calls for providers to show their ‘value’ by reducing

costs, so CMS is buying good ‘value’ with their Medicare dollars. Currently, measures are based on re-hospitalizations.

4/15/2018

16

SNF VBPResult of PAMA of 2014 enacted 4-1-14 under Social Security Act• Focus of the program:

– Performance standards including ‘achievement’ and ‘improvement’ ratings

– Rank SNFs for from low to high based on performance– 2% of PPS/Medicare payment withheld to fund program– Incentive payments to providers must total 50-70% of amount

withheld– Incentive payments=buying your money back, up to 2%

• Both measures are based on hospital readmissions– SNF PPR- potentially preventable, risk adjusted (will replace RM)– SNF RM- all-cause/condition, original measure (begins 1-1-17)

• Payments affected 10/1/18

SNF VBP Re-hospitalization Measure RM

‘Improvement’ Rating up to 90 points

________________ 2017 your SNF

________________ 2015 your SNF

Better of the two, Improvement Rating or Achievement Rating

SNF VBP Re-hospitalization measure RM

• If your SNF meets the BENCHMARK, then your rating is 100. • If your SNF doesn’t meet at least the 25th percentile, then your rating is 0.• Remainder will be disbursed, 0-99.

_______________ 2017 your SNF

_______________ 2015 ALL SNFs

Benchmark: Average top 10% performing SNFs in 2015 (83.6)

Achievement Rating: SNF reaches 25% threshold (20.41)

4/15/2018

17

SNF VBP Measure• Results in achievement rating score based on percentage of residents

that were not readmitted during the window• Compares value rating scores between providers• How did you do in 2017 compared to all SNFs nationwide in 2015?

– If you did better than benchmarks (100 points)– If you did worse than achievement threshold (0 points)– All facilities in between points assigned based on “Achievement

Score”• Second score “Improvement Score” based on how well your facility did

in 2017 compared to your 2015 data – Above benchmark (90 points)– If worse than 2015 (0 points)

Performance Scores

The lower the readmission rate, the better.

Since a lower readmission rate is better, CMS has inverted every SNF’s readmission rate using (1 –readmission rate) for the purposes of the performance standards (i.e., benchmark and achievement threshold) and performance scoring.• Standard 2015• 25th Percentile 20.41%• Achievement Threshold 79.59%• Mean of the Best Decile 16.40%• Benchmark 83.60%

2015 Performance Data

4/15/2018

18

Risk Adjustment

• Example risk adjustment variables include the following (List is not all inclusive): patient demographics (e.g., age and sex)

• principal diagnosis in the prior hospitalization• comorbid conditions• disability as the original reason for Medicare coverage• health service factors (e.g., length of stay and any time spent in

intensive care unit during the patient’s prior proximal hospitalization)

• https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/Other-VBPs/SNF-VBP.html.

Excluded Re-hospitalizations

SNF stays where: There was an intervening post-acute care admission within the 30-day measure window• There was more than 1 day between the prior proximal

hospital discharge and the SNF admission• The patient was discharged from the SNF against

medical advice• The principal diagnosis from the prior proximal

hospitalization was for pregnancy• The principal diagnosis from the prior proximal

hospitalization was for medical treatment of cancer

Potential Additions to the Provider ReportsPatient-level data elements currently being considered for inclusion include:• Patient identifiers (Health Insurance Claim Number [HICN], Sex, Date

of Birth)• Index SNF information (admission/discharge dates, discharge status

code)• Prior proximal hospital information CMS Certification Number [CCN],

admission/discharge dates, discharges status code, principal diagnosis)

• Readmission hospital information (CCN, admission/discharge dates, principal diagnosis)

• SNFRM risk-adjustment factors

4/15/2018

19

Supplemental Workbook -Eligible Stays tab-21

PATIENT CHARACTERISTICS INDEX SNF INFORMATION PRIOR PROXIMAL HOSPITAL INFORMATION

ID Number

HICN Sex Age

Admission Date of

Index SNF Stay

Discharge Date of

Index SNF Stay

Index SNF Discharge

Status Code

PriorProximalHospital

CCN

Admission Date of Prior

Proximal Hospital

Stay

Discharge Date of Prior

Proximal Hospital

Stay

ICD Version of Principal Diagnosis

(Prior Proximal Hospital)

Principal Diagnosis of

Prior Proximal

Hospital Stay

Modifying Data

It is the responsibility of each SNF to provide corrections to information prior to the time of public reporting.•CMS has finalized a process where the quarterly reports will provide SNFs with:• A count of readmissions• The number of eligible stays at the SNF• The SNF’s risk-standardized readmissions rate • The national SNF measure performance rate

SNF VBP Preview Reports

4/15/2018

20

Modifying Data

• For the first phase, SNFs must submit correction requests for their quality measure data to SNFVBPinquiries@cms.hhs.gov and provide the following:

• CMS Certification Number• Facility name• Correction requested and basis for the correction• Appropriate documentation or other evidence supporting

the request

Modifying Data

• Phase One corrections are limited to review and correction of SNFs’ quality measure information.

• Phase Two corrections are limited to SNF’s performance scores and ranking.• CMS will propose more specific requirements for Phase Two corrections in

the future, and welcomes feedback.• Correction requests to the contents of any quarterly report will be accepted

until March 31 following the report’s delivery.

If corrections are provided after information is publicly reported but before the March 31st deadline, corrections will be made retroactively. CMS will review the requests and notify the requesting SNF of the final decision.

Retrieving SNFVBP Reports

4/15/2018

21

Provider Reports

Resident Classification System (RCS-1)

Resident Classification System (RSC-1)

• PPS is resource use based, incentivizing use of rehab therapy for higher revenue– Rehab RUG levels became targets

• Complex medical admissions support therapy• CMS will create disincentive for SNFs to push up rehab RUG

levels

• RCS will be based on resident conditions

4/15/2018

22

FY 2018 Rate Methodology

• Market basket changes– Predicted an increase of 2.7% and no Productivity adjustment

due to prior year showed no increase• 2016 market basket 2.3, actual increase 2.3 =0% change

– Actual market basket increase of 1% • CMS implemented a Special Rule stating that the FY 2018 market

basket must equal 1%• No Multi Factor Productivity adjustment applied (0.4%)

– May also subject to 2% reduction related to SNFQRP data under 80% of total MDSs & 2% VBP

• Wage Weighted Staff Time– Based on 2014 Nursing RUGs (43)

Wage Weighted Staff Time

• STRIVE data separated by resident specific time (direct care) and job title=nursing costs

• Sample size limited to 2,310 stays, most MACs do not reimburse in lower 14 nursing RUGs

• Applied to each non-rehab RUG (43) for FY 2014• Average CMI was set to 1.0

4/15/2018

23

FY 2018 Rate Structure

FY 2019 Rate Structure

FY 2018 Rate Methodology

• 2014 claims data was extrapolated to study SNF billing patterns and resident characteristics and learned where costs decreased or leveled off and what resources were used through the length of stay– Diagnoses, length of stay, ARDs, RUG level per

beneficiary

4/15/2018

24

FY 2018 Rate Methodology

• Acumen research linked costs to beneficiary characteristics then verify via provider info using cost reports and wage data to estimate beneficiary costs

• Normalized for all SNF sizes• Cross referenced via CASPER reports• Backed into costs using CCR from cost reports

– Cost-to-charge ratios

FY 2018 Rate Methodology

• Do you include all charges on claims by revenue code? $58/day higher than average– IVs separate from drugs– Specialized services

• Hyperbaric chambers• Wound supplies• Enteral feeding supplies

• Did you have accurate diagnosis codes? or….• V57.89 Multiple therapies

Cost of Inaccurate Diagnoses

• Prior hospital stay diagnoses used because 47% of providers used generic procedure codes rather than diagnosis codes like V57.98 (multiple therapies)

• Does not reflect primary reason for skilled care, irrelevant to describe resident condition

4/15/2018

25

Diagnosis & Conditions –Applicable to

RCS-1 and SNF QRP

Co-morbid Conditions

• Diagnoses mapped to condition categories (clinical groupings)

• Data obtained through MDS assessments and 1 year look back to other providers (MD, Hospital, OPT) to identify chronic conditions

• ICD-9 codes (2014)

Co-morbidity Score

• A count system will be summed to assign payment rates based on the number of comorbidities present and based on the number of comorbid conditions and costs– Higher payments for those with more co-morbidities

• Diagnosis coding!!!• NTA costs higher for those with higher multiple comorbid

conditions

4/15/2018

26

FY 2018 Rate Methodology

• Base Rate + CMI + Adjustment factor• CMI dependent on resident classification assigned

– Nursing– PT/OT– SLP– NTA

RCS-1 Rates Urban-

example

$100.91 X Nursing RUG CMI =

76.12 X NTA CMI X Adjustment Factor =

126.76 X PT/OT CMI X Adjustment Factor =

24.14 X SLP CMI =

90.35 X 1= 90.35 (Non-case mix component)

RCS Payment

Calculation

4/15/2018

27

PT/OT

• Based on hospital diagnoses– Separated surgical DRGs from medical DRGs– Surgical further divided by Ortho and Non-ortho

• Cognitive status• Functional status

SLP

• Based on hospital diagnosis– Cognitive status– Speech related co-morbidities– Swallowing problem– Mechanically altered diet

SLP Related Co-morbidities

4/15/2018

28

Nursing

• Based on clinical diagnoses from SNF stay• End Splits

– Extensive services– Depression– Restorative nursing

NTA

• Non-Therapy Ancillary Services• Based on co-morbidities• Extensive Services

– Isolation– Tracheostomy– Ventilator

Non-case Mix

• Therapy evaluations• Other items related to therapy for non-rehab RUG groups• Room and Board

4/15/2018

29

Adjustment Factor

• Claims showed that costs reduced depending on LOS• Variable per diem schedule based on day of stay• Will reduce PT/OT by 1% per day after day 14

– So day 15 will be day 1 with a 1% reduction through day 100 (71%) of PT/OT costs

• NTA costs drop after day 3 ($150 vs $47/day)

4/15/2018

30

RCS-1 Rate Structure

Nursing: 100.91x 2.27 (HE2) $229.06+

NonTherapy Ancillary 76.12 (NTA) x 3 (adj) $228.36+

PT/OT: 126.76 (PT/OT) X 2.73 (TC) X .99 (adjustment factor day 17) $342.59+

SLP: 24.14 (SLP) X 2.54 (SF) $61.32+

Non-Case Mix: 90.35

Total Rate= $951.68

Clinical Condition Categories

PT/OT Clinical Categories

4/15/2018

31

Diagnosis Crosswalk

Diagnosis Crosswalk

Cognitive Function Scale

Combines BIMS and Cognitive Performance Scales to compare cognitive function across all residents

– Makes self understood– CPS (coma, ST memory,

decision making, ADL)– BIMS (interview or

assessment)

4/15/2018

32

Functional Score PT/OT

• Based on 3 ADLs (Bed Mobility eliminated)• Range 0-18

– Therapy costs increased then decreased with greater dependence in regard to toileting and transfer

– Costs increased with independent level for eating– Limited assist resulted in highest PT/OT costs (6pt)– Extensive assist, results in 5 points

Functional Scoring

• 3 of the 4 late loss ADLs will be used to determine functional score

• Bed Mobility is not utilized• Only Self Performance is used, Support is ignored• Uses ‘Activity Happened Once or Twice’ (7)• Uses ‘Activity Did not Occur’ (8)

PT/OT Functional Score: Transfer/Toileting

4/15/2018

33

ADL Points for Functional Score

Classification and Regression Tree

• First start with clinical reasons using 1st line on Section I diagnosis coding– This will be the field for primary diagnosis

assignment • Then for PT/OT the Functional score is determined,

then Cognitive Functional Score• For SLP, the presence of a swallowing

disorder/mechanically altered diet, SLP comorbidity, then cognitive impairment

CART Regression Assignments for Final Group

• 30 case-mix groups for PT/OT• 18 case mix groups for SLP• 43 case mix groups for Nursing• Total of 91 possible CMI groupings • 6 NTA add-ons

4/15/2018

34

CART for PT/OT

CART for SLP

4/15/2018

35

CART for SLP

Classification and Regression Tree

• First start with clinical reasons using 1st line on Section I diagnosis coding– This will be the field for primary diagnosis assignment

• Then for PT/OT the Functional score is determined, then Cognitive Functional Score

• For SLP, the presence of a swallowing disorder/mechanically altered diet, SLP comorbidity, then cognitive impairment

Nursing CART Assignment

• First assigns the Non-rehab RUG assignment• Then assign weights for WWST (wage weighted staff time)• Apply end-splits

– ADL score– Depression score– Restorative nursing

4/15/2018

36

CART for Nursing

NTA Classification

• 2 tier assignment• Uses both resident conditions or diagnoses• Then determines use of extensive services

4/15/2018

37

Determine NTACase Mix Group

using Score Total for all

Comorbidities

NTA Score Range NTA Case-Mix Group NTA CMI

11+ NA 3.33

8-10 NB 2.59

6-7 NC 2.02

3-5 ND 1.52

1-2 NE 1.16

0 NF 0.83

NTA Comorbidities with Highest Points

• HIV (8 points)• High-Intensity Parenteral/IV Fluids (7 points)• Low-Intensity Parenteral/IV Fluids• IV Medication• Ventilator Use

(5 points)

4/15/2018

38

Adjustment Factors-NTAPT/OT

NTA Adjustment Factor

RCS-1 Rate Structure

Nursing: 100.91x 2.27 (HE2) $229.06+

NonTherapy Ancillary 76.12 (NTA) x 3 (adj) $228.36+

PT/OT: 126.76 (PT/OT) X 2.73 (TC) X .99 (adjustment factor day 17) $342.59+

SLP: 24.14 (SLP) X 2.54 (SF) $61.32+

Non-Case Mix: 90.35

Total Rate= $951.68

4/15/2018

39

MDS

• Version 1.16 will have multiple changes related to RCS and new QMs for SNFQRP

• Transition/Effective date 10/1/18• ADLs used for Non-rehab RUGs for Nursing component• Functional score used for PT/OT component• Will add a section for Primary diagnosis

MDS Schedule

Interrupted Stay Policy

• Discharge of less than 3 days will not require a new MDS, same RCS level will continue

• Payment will resume at prior RCS,(same SNF)• Significant Change will take precedence and allow

changes to RCS level• Must meet same clinical criteria to perform SCSA • Discharge to new provider will restart with 5-day

4/15/2018

40

Interrupted Stay Policy

• Readmission to the same SNF after discharge 3 or more days, will require new 5-day MDS

• NTA is reset to initial adjustment factor (Day 1)

Highest Paying RCS• Acute Neurological with both swallowing problem and

mechanically altered diet• Average of $130.14 with CMI 4.19• Total add-on for all 3 therapy disciplines

– $387/day which is higher than RUG IV at approximately $249/day

• May want to utilize therapy provision in a similar way to managed care– We can afford to spend X amount based on reimbursement

Questions??

Maureen McCarthy, RN, BS, RAC-MT, QCP-MTPresident, CEOPhone (Office): 860-321-7413Email: mmccarthy@celticconsulting.org

www.celticconsulting.org