Whats new from medicare consultant
April 2011
April
29th: CMS published the
2012 Interim Final Rule for SNF and gave the industry a jolt. The
proposal includes adjustments to payment structure that can result in
less than a $4 billion decline in payment, also clarification of
the missed 72 hrs of therapy regulation. In addition to that
clarification came another OMRA to be finished in conjunction with
the EOT OMRA in the event the patient resumes therapy within 5 days in the
EOT.
Let's focus on the biggy once we say within the
UK, the ability will have to evaluate the patient treatment outside
in the observation period and if it is significantly not the same as
the RUG level these are being paid then this Change of Therapy (COT)
OMRA will probably be completed to produce the new payment level. This review is to
be practiced weekly and should finally stop the alterations in treatment
some time and modes of treatment that we know occur in some facilities. Documentation will probably be under scrutiny to aid the assistance being
provided along wit identification for the POT to compliment group
treatment.
Also changing include the optimal
assessment reference dates to reduce the "double dipping" of
treatment minutes to generate 2 different RUG levels along with the
amount of grace days that is reduced to 4 days for those other
compared to 5-day. (Maybe they finally read my comments about reducing
those dates that we entered as comment to the Final Rule about 5
in years past).
Group treatment has become redefined to
produce a group to consist of 4 patients and, in the calculation in the
RUG, only 25% of group minutes is going to be counted combined with the
current restriction of 25% from the total minutes originating from group. Very good news could be that the direct line-of-sight supervision of students
has been eliminated.
And that we have to blame No-one
but ourselves. Whenever CMS changes payment structure, we changed
how we practiced. In line with the STRIVE report, the calculation RUG IV
were developed. The STRIVE report established that there is minimal
use group treatment with a lot of treatment being individual or
concurrent. The information collected through the new system indicates
dramatic lowering of usage of concurrent, but significant surge in
group treatment.
We'll be preparing a more in-depth
breakdown of the proposed modifications in the subsequent few days. We also will
be updating our Mastering Medicare Seminar to add the alterations
once the Final Rule is posted at the final of July.
Our news is always that our new website is
almost ready to go live and that we hope you will relish it and find it
much easier to negotiate. This, along with another factors has been
why April continues to be without updates. Using the new website, that
ought to be resolved, so stay tuned.
March 2011
March
29th: Well, March is a huge
quiet month for news! Unfortunately, it's been a lively month for me and achieving to update
the site has been difficult.
I have had several people send an email
to see if I heard back from your CMS SNF Open Door team on the
questions I sent them in January concerning the EOT OMRA whenever a patient
misses era of therapy, and guess what happens the reply is! NO. The
questions were also not answered on the March 17th SNF ODF either.
At the March 17th meeting, the niche
was described plus it was acknowledged until this requirement is NOT
in the RAI Manual. It had been brought up that requirement was at
statute and had been addressed inside the FR in 2010 FY. Checking back,
guess what happens I found. The reference would have been to section 409 from the Code of
Federal Regulations covering extended care services. It
identifies that skilled therapy services under Part A SNF must be
provided at the very least of Five days a week. The section procedes state
that " a good intermittent missed treatments for 1 or 2 days is not going to
compromise the Part A coverage. " and "most SNFs provide Five days a
week coverage". The interesting fact is that statute may be
in position for quite some time and is at place when mentioned during 2009 and
we had been using the MDS 2. 0. And so i guess my question is "Why has got the
CMS SNF group thought we would implement this regulation as soon as the
working out for MDS 3. 0 along with the publication from the RAI Manual"
Anyhow, seeing non of them probably
see this column, we will probably can't predict. So, the best which i
might get away from that audio cast was actually focusing on it! The modern RAI updates will "probably" address it and it is something
that's not going to vanish entirely.
Determined by all the details I've
been able to have, the info in the January section still
applies. My recommendation if it, unless you haven't provided
services over a weekend, in that case your facility could easily get away while using 2
missed days plus Saturday and Sunday. Because so many facilities happen to be
able to give you a services on a weekend, either just because a holiday
was occurring through the week, or a patient what food was in an observation
period and the ARD couldn't be moved, then you might see that this
new interpretation refers to you.
Just how do or not it's managed Well,
in case a patient misses days throughout the week, when the second treatment
is missed then that day, the team may need to look at why of course, if the
patient can be viewed the very next day. Remember, this only applies when
all disciplines are missing treatments. When it seems to be when the 3rd
treatment day will probably be missed, then a EOT OMRA should be
done on Day 3 to stay compliance (ARD day 1, Several as soon as the last
therapy). Let's focus on the tricky bit, has nursing been providing any
skilled nursing services: or else, chances are they better be addressing the
basis for the missed therapy. WHY Well, the EOT OMRA carries a look
back of 7 days, just like others and produces a nursing RUG payment
applicable from the next day the very last therapy. If no skills have
been provided then a MDS might not also be capable of meeting a talented
amount of care. WOW! Then what
This case seemed to be discussed as
guess what happens has not yet happened; the SNF ABN hasn't been issued and also the
patient hasn't been informed with the coverage ending and the
nightmare continues. I am not sure what number of you scanning this
listened to the audio conference, but, at this time, someone made
the comment that when not seeing the person around the Saturday and
Sunday counts as 2 missed days and after that, because tips over
for the Monday so that the patient isn't seen and nursing hasn't
been providing skilled services, should they have given the patient
the ABN around the Friday and should this be achieved ought to be course. The first answer were yes, after which, even as have learned to
expect readily available meetings, the speaker declared that she wasn't meaning
that this should be done. Well, it sure sounded prefer that if you ask me.
Out of your tender we're, no further forward
plus more confused than previously. My recommendation, be sure that
someone can provide a weekend treatment if Friday is missed, and
essential if Thursday and Friday were missed. This example, unless
clearly resolved, could end up being the RACs favorite new
issue.
Stay Tuned.
February 2011
February 21st: The Department
of HHS announced which a
combined action with the HEAT task forces had made arrests in numerous
areas including Brooklyn, L . a . , Detroit and Miami. The round
up follows investigation of fraud in billing Medicare services and
identified over $240 million in fraudulent claims. Unfortunately
Physical Therapy was one of several Medicare benefits that has been under
scrutiny with at the very least three different schemes. An actual physical Therapist
in Nyc was accused of fraudulently bill over $11. 9 million in
claims between January 2005 and June 2010. These claims were either
for services not performed or medically unnecessary.
This find follows closely around the
heels from the OIG report that identified the 2 counties of Queens
and Kings as 2 in the 20 counties having massive overutilization of
therapy services. Our latest edition from the e-newsletter contains
our editorial writeup on both of these reports. To gain access to the Part B
report
follow this link and for the SNF
report
follow this link.
February 5th: The
government's fight against the increasing prevalence in Medicare and
Medicaid fraud has gotten a new turn which puts a spotlight on PTs in
private practice above other therapy providers! Starting March 25th
2011, additional provisions are applied to screen new
providers and suppliers of Medicare services, together with existing
providers and suppliers who're revalidating their Medicare
participation.
The newest regulations outlined inside
Final Rule published February 2nd, authorizes 3 levels of additional
screening depending on assessed risk. Within the new rule
CMS will require Medicare contractors to
screen all initial applications, including applications
to get a new practice location, and any application
received in reaction to a revalidation request. A few
levels provide
Limited, Moderate and
Categorical Risk.
Limited risk
includes amongst others OTs and SLPs in Private practice, Skilled
Convalescent homes and Rehab Agencies;
the screening
requirements are:
1) verify the provider or supplier meet the Federal regulations
while stating requirements for your provider type prior to enrollment;
2) conduct license verifications;
3) Conduct database checks on pre and post enrollment basis to
ensure that providers and suppliers meet enrollment criteria for
their provider/supplier type.
Moderate risk
includes a few
Physical therapists enrolling as individuals or as group practices
and comprehensive outpatient rehabilitation facilities.
The
screening includes what's needed listed above
PLUS
on-site visits.
The
Dangerous category
includes new HHA and DMEPOS
providers, however! ! ! ! ! ! ! Any therapist in private practice that
wants to provide DME, orthotics or prosthetics to the patients will
ought to match the same screening requirements since the DMEPOS which
are:
1) Every one of the
requirements for limited and moderate risk level;
2) Submission
of an set of fingerprints for the national background
check from all folks who maintain a Five percent or greater
direct or indirect ownership desire for the provider or supplier;
and
3)
Fingerprint-based criminal background record check from the FBIs
Integration Automated Fingerprint Identification System on all
folks who have a Five percent or greater direct or indirect
ownership interest in the provider or supplier. This must be done
upon submission of a Medicare enrollment application and within 30
events of the contractor request.
As if this wasn't enough, the rule
also imposes application fees on institutional providers
and provides CMS new authorities to put moratoria and
suspension of payment holds on specific provider types when
fraud, abuse or waste is suspected. (Note: suspected
NOT proven. )
We've famous for for a specified duration that
there was a significant amount of both abuse and fraud being
completed by the supply of Medicare part b services, now we all have been going
to become paying the price of a few. This rule follows hard on the heels
from the OIG reports indicating over by using both Medicare part b
services in 20 counties in the united states with Miami/Dade County receiving
special recognition as having 4 times all the utilization compared to
National Average.
January 2011
January 31st: Last
Thursday, in the SNF Open Door call, the speaker addressed the
CMS insurance policy for the EOT OMRA in the event the patient has missed 72 hours of
therapy. The result for myself and i am sure a lot of the listeners
was more confusion. I've an e-mail into the speaker with
definitive questions which i hope will pay off the confusion buy altace without a prescription. The following is
the non-confused information I got in the call.
Whenever a patient misses Three days of
therapy then an EOT OMRA should be completed. The days refer to
therapy overall, not each services therefore if PT misses Three days
but another therapy misses only Two days prior to the patient resumes
care than the would not apply. If the facility provides 7 day
therapy, then a patient must miss 3 consecutive days, so
for example. The person receives no therapy service on Friday,
Sunday, then an EOT must be done. Now it gets
interesting! In the regulations when the ARD of the EOT must
occur, it states that it may be day 1, Several as soon as the last day
that therapy was provided, which presumably means that Sunday would
become the ARD. So one could presume that right after the therapist
determines that there's no chance to offer at least 15 minutes of
therapy on that day, the MDS coordinator has to be able to fix tomorrow
because the ARD in order that they are certainly not out of compliance using the
regulations.
Now comes the confusion in what
actually defines what number of days every week a facility provides therapy. In the past calls, and also at conferences, Ellen Berry, the PT
who works best for CMS states if you demonstrated the ability to
provide a services on the Saturday or Sunday, which makes you a Six or seven
day week department. The speaker on Thursday said that a friendly
provision of therapy will not cause you to a Six or seven day department. First confusion! Next she begun to offer an example of a five
day clinic but appeared relating returning to the 7 day clinic, so a
clear defined answer or example never was given.
One caller provided among the
undeniable fact that their facility provides Monday thru Friday only coverage,
but, as a result of holidays, they provided services around the Saturday
and Sunday before in order that the staff may have the Friday holiday
off. The resultant answer was that, given that they missed Friday
End of the week, they really should have done a EOT since the
patient missed 72 hrs, although patient had received the
therapy needed by the POT. Second confusion!
Once I obtain the solutions to my
questions I'll post them on this site along with the meantime, the
moral with this story definitely seems to be, get A quarter-hour of any therapy done, when it
appears like the individual will probably miss 3 consecutive days or
never treat on the Saturday or Sunday to help you truly say you
really are a 5 times per week clinic. Ah Government, and the interesting
thing is, this policy is not down on paper in the RAI Manual. I'm
presuming that will probably be remedied inside updates which can be
expected early in the year.
January 10th:
Late a few weeks ago, the OIG
released two reports on Questionable Billing Practices,
one for Medicare Outpatient Therapy Service as well as the other for SNF
Part A Services. The findings both in of those reports was of high
overutilization of services with both abuse and fraud occurring. The
strategies for these two reports were to increase scrutiny
of claims submitted and institute changes to the techniques payment
of those services are made.
Whatever they found: For outpatient therapy
services, 20 counties were identified that, during 2009, had provided 1)
the highest average Medicare payments per beneficiary and 2) had
services that produced a lot more than $1 million as a whole Medicare
payments, i. e. high utilization counties. For SNF, it absolutely was determined
that from 2006 to 2008, 1) billing for high paying RUGs increased
though beneficiary characteristics remained generally
unchanged, 2) To make money SNFs were prone to bill higher paying
RUGS these days to make money or government SNFs, and 3) Some hadt
questionable billing practices with higher RUGs and long length of
stay (total of 348 of facilities in study).
What do i mean for us
MORE Medical Reviews!
Who must be concerned
Well, for OPT,
Miami-Dade was analyzed separately all others because it has a much
higher by using all counties. The opposite 19 counties included 6
counties in Louisiana, 4 in Texas, 3 in Mississippi, 2 in Indiana, 2
in The big apple, One in Georgia and another in Florida.
For SNF, large companies had the
highest utilization of high RUG levels, mainly RU groups, having a
noticeable rise in utilization when they purchased new
facilities.
Do you know the triggers
For OPT, the use of the
KX modifier both during treatment and so on initial therapy visit,
treatment all through the year along with services by multiple
providers; also included is treatment exceeding 8 hours each day. For
SNF, high use of RUG Ultra levels along with over average
length of stay far better than average ADL scores. The report also
identified used of ICD-9 codes with V57, care involving use of rehab
procedures, increasing 4. 9% by 50 percent a number of heading their set of
codes.
We will be creating a summary of
both reports and possess them posted over the following day or two.
December 2010
December 24th:
The APTA
sent updated information to its members on the effect with the MRRP
policy. It established that the negative effect from the MPPR is offset
with a blend of the PPIS survey data along with the Medicare Economic
Index rebasing. The notice established that the web impact of such
changes all combined will be a negative impact around 5%. They
didn't differentiate between whether it was for the 20% or 25%
decrease. Seeing that the APTA predominantly issues information
effecting the non-public practitioner, we're making, a presumption
this 5% affects PTPP, and so the institutional based practices,
including CORFs (Rehab Agencies) and CORFs might have a poor
impact a better view as have been initially indicated according to
practice patterns, of 6% to 7% from 2010
December 23rd: CMS issued the
transmittal explaining the MPPR policy. The insurance policy is effective January 1st
for many providers and suppliers of Part B services, however, the
lowering of the practice expense is unique for Therapists in
Private Practice from that relating to institutional providers. Under the
regulations, "suppliers" of Part B services, i. e. therapists in
private practice, that provide services within an office or
non-institutional setting are at the mercy of a 20% reduction
inside the practice expense (PE) as provided in the Physician Payment
and Therapy Relief Act, whereas institutional providers i. e. All the Providers, will dsicover the 25% reduction
in the PE area of the billed units as originally announced in the
November Final Rule. The Medicare Economic Index was announced and
offers a negative 2% rebasing of values to the 2011 Fee Schedule. To see the CMS transmittal,
follow this link and also to read
the MLN interpretation,
follow this link.
December 20th:
The on December 15th, obama signed into law the Senate
Amendment to HR4994 such as the provisions identified below. This amendment did not address the MPPR scheduled for January 1st
2011. Also what's not been released will be the Medicare Economic Index
for 2011. This may have a very 7% to 8% negative impact as outlined by
Rick Gawenda, PT, President of the APTA's Health Administration
Section. So as there is overall nice thing about it, we still do not know
the actual financial influence on Part B services for 2011.
Can you still claims for just about any
services provided during 2009 that you've not filed If you have, you
better buy them submitted before December 31st or they shall be
denied. Also, the individual Protection and Affordable Care Act (PPACA)
instituted a single year time period limit to file claims. Therefore, effective
January 1st 2011, services is going to be automatically denied which are
over the age of 1 year or so.
In
general, the commencement date for determining the 1-year timely filing
period may be the date and services information or From date on the claim. For
institutional claims offering span dates of service (i. e. , a
From and Through date about the claim), the Through date for the
claim is used for determining the date of service for claims filing
timeliness. For claims submitted by physicians along with other
suppliers that include span dates and services information, the line item From
date is employed for determining the date and services information for claims filing
timeliness.
To
look at the Medicare Learning Network Article follow
this link for SNF
and
this link for Part B Services.
December
10th: WOW! Merry Christmas
from Congress. Congress passed the Medicare and
Medicaid Extension Act providing therapists which has a very welcome 2011
gift. The first time, therapists under Medicare part b understand what to
expect come January 1st 2011.
We now have the extension with the
therapy cap exception process till 2012
We've got the identical reimbursement
fee schedule as 2010 with continuation in the 2. 2% increase
instead of the forecasted 25. 5% decrease
The proposed 50% loss of the
practice expense over the MPPR was decreased to 20%, thus
making the decrease in overall revenue a manageable (form of) 4%
to 5% decrease from 2010.
Congress also gave CMS a gift too. They repealed the delay in implementing RUG IV meaning that CMS does
not need to spend any more time or any more of our own money creating
the hybrid RUG III software and SNFs don't have to go through a
period of having their claims recalculated and monies returned. Therefore, both CMS and SNFs is now able to focus on obtaining the MDS 3. 0
and RUG IV system to produce sense.
December 1st: Yesterday
obama signed PPTRA into law, providing to get a continuation of
the actual fee schedule up until the end of the season. The expense of the 1
month extension will be paid for while using 20% MPPR decrease
effective January 1st 2011. However, during the last weeks with the
present session, the SGR shall be addressed in order to be proactive
concerning the scheduled 25% decrease at the time of January 1st. Additionally it is
hoped that included would be the therapy caps along with the extension of
the exception process. Uncertain when we should be holding our breath
on any particular one! It would be an initial.
CMS issued the last Rule for that
Physician's Fee Schedule on November 29th, and after this must
address the newest changes.
November 2010
November 19th: Well,
the first type of great news
for a while! Yesterday the US Senate passed health related conditions Payment
and Therapy Relief Act (PPTRA) which extends the two. 2% boost in
the charge schedule over the end of the season. This act also reduces
the 25% decrease in the PE reimbursement to 20%. The scheduled
decline in the charge diary for 2011 of around 25% wasn't
addressed.
The American Medical Association
is encouraging Congress to cope with the implementation of RUG IV, so
concerning slow up the disruption that would occur using the payment
system. The house has now passed bills which would implement RUG
IV payments at the time of October 1st 2010 rather than current schedule
of 2011. CMS has addressed this of their open door sessions as they
are having to formulate a hybrid system that will recalculate the
current payments to some mix of RUG III as well as the MDS 3. 0. Essentially
which means that you will have a recalculation of payments and very
likely refunds to Medicare. The price of doing this along with the
disruption it might cause is simply another example of the effects of
the HealthCare legislation which "had to be passed and we all would then
determine what is at it".
Additionally they addressed the extending the
exception process for Part B therapy caps as the impact on this cap
for the residents of Skilled Nursing Facilities gets the most negative
consequences coming from all Medicare beneficiary groups.
Hopefully. the "lame duck" congress
can get their act together finally all of the campaigning ends and
start making sense from what they are doing! !
November 3rd: It's official,
therapists will be in to get a loss of reimbursement starting January
1st. Yesterday, CMS
published the last Rule for 2011 effecting reimbursement for Part B
services.
Good news:
the Therapy Cap has grown an astonishing $10 to 1870 per cap,
Not so great news: We still need the caps in place with out exception
process for 2011 unless addressed by Congress. Great news
according to CMS: The cap goes father enabling the
beneficiary to possess more therapy before the cap is met! ! ! !
Not so great news: CMS is
implementing the multiple procedure reduction policy (MPPR),
Very good news: it's 25% in the practice expense RVU from the fee
schedule, not the 50% initially proposed. CMS indicated that it has
estimated that this will result in a 7% to 9% lowering of payments,
not the 11% to 13% within the proposed rule! ! !
Bad News: The MPPR
relates to all "always therapy codes" given by the
provider/supplier towards the beneficiary per day. Which means that for
institutional providers it pertains to therapy services performed
on that day, the same as the CCI edits. It's provider specific not
discipline specific, therefore, if a mix of PT, OT and SLP
services are supplied on the same day, the more costly code
billed by some of the disciplines will likely be paid fully while rest of
the claim will be be subject to the MPPR reduction. It also refers to
BID treatments since it is day specific not treatment session or visit.
Also within the FR, CMS will continue to
address the variety of reimbursement of therapy Part B services.
October 2010
October 28th: SNF Open Door
Forum held today still
reflected the confusion that's MDS 3. 0 and RUG IV. Until repealed
by Congress, CMS is still delivering for the progression of the
hybrid RUG III payment system and established that the grouper to
recalculate the RUG payments ought to be ready inside Year. Talk
regarding your tax dollars in the office. Your house passed the repeal on this
requirement ahead of the recess but the Senate is still equipped with to vote onto it
before it could become official, that's RUG IV payments are valid
from Oct 1st 2010, not 2011.
The speakers frequently mentioned
"listening to comments" manufactured by providers and are working on
updating the RAI Manual, to deal with concerns raised. This new manual
should be published in Spring 2011.
The subsequent Open Door Forum around the MDS
3. 0 is scheduled for November 9th. Hopefully it's going to throw some
light around the technique EOT OMRA in the event the patient misses visits. We
could keep you posted.
October 26th: Most people are
waiting for the FR for Part B services to become published. There's no indication of
whether the proposed modifications in the Fee schedule will probably be changed in
the now much awaited publication with the 2011 FR, effective January
1st 2011. To compound the concern, the delay of the implementation
in the 21% plus reduction in payment that has been delayed by Congress is
scheduled to run out on November 30th. Whether this is
addressed from the "lame duck" session before the Christmas recess
is anybodies guess.
Having only finished our seminars on
Medicare Part B, we had arrived on occasion capable of deliver a
positive try to find Rehab in 2011.
October 1st: Well, the MDS 3. 0
is official. At the time of
today, therapist are working within a new list of regulations in
Skilled Nursing. Rules so new some of them still need wet ink!
CMS clarified the way to code create
minutes on September 23rd. The minutes allocated to build time,
provided by an aide, therapist or therapist assistant might be counted
and included as skilled services. What CMS clarified was the the
minutes are invested in the mode of therapy services which is being
ready for. individual, concurrent or group.
Therefore if the aide is preparing an area
for your therapist to supply group therapy, then a minutes wound
be included within the group therapy time.
Congress adjourned this week without
addressing any of the therapy concerns regarding the
expiration of the current fee schedule levels set to switch
on December 1st, setting up a 21% plus decrease for Medicare part b services. There was no action to combine the 2 main bills addressing the rescinding
in the delay in the implementation of RUG IV till pick up.
September 2010
September 3rd: The
special open door around the MDS 3. 0 was definitely the best information
provided yet. Ellen Berry, PT, a part from the CMS staff presented
information about the usage of the short stay assessment, the beginning of
therapy (SOT) OMRA and also the end of therapy (EOT) OMRA that may come
into effect October 1st. The presentation dispelled some of the
confusion but revealed the need for focusing on how the MDS
grouper will continue to work understanding that, due to reimbursement for a lot of of the
nursing RUGs, it can be financially good for the ability not
to do a short stay assessment since the payment may be better for the
nursing RUG.
The EOT OMRA is a mandatory
assessment that must be completed if the resident is remaining within the
Part A stay being skilled by nursing. THE SOT and the short stay
assessments are voluntary assessments the facility team will
choose to use or not.
We will be incorporating all this
into our Made Easy Seminar in addition to some assessment tools/cheat
sheets to the MDS coordinator and therapy to do business with.
A subject mentioned in the Q&A was
in regards to the way the grouper would trigger an EOT OMRA if the
resident misses more than 72 hrs of therapy. The question was asked
how ps3 slim be handled, as, the flu season is coming and
residents may miss some treatment days along with the timing in the EOT,
then performing a SOT which technically isn't a new beginning of care and
therefore might generally not necessitate a fresh eval and POT. The
CMS panel indicated that they would explore this and present guidance
with the next ODF.
August 2010
August
29th: Last weeks special open
door forum about the MDS 3. 0
was mainly focused on the
transitional period from your previous couple of events of September and the
first few days of October for the patients have been in a
observation period. The periods in September will be covered by the
MDS 2. 0 as well as the days in October by the MDS 3. 0. Discuss
confusing! ! ! CMS has a produced several excel files which might be
positioned on the MDS website for MDS Coordinators to get the
different days included inside observation period. One of several
options was just to take the default rate for just one or 48 hours and
then submit these. 0 for the balance. The slides can be purchased and a
recording of the audioconference is going to be published on his or her site. Unfortunately, some people stood a break in contact with the conference
call and lost about 20 mins of information. When it absolutely was
resolved the Q&A was already in session. The final get in touch with this
series are these claims coming Wednesday so hopefully many of the questions
about the short stay assessment will probably be clarified.
For the time being, CMS launched its
demonstration to formulate a different payment system to the
current Medicare cap and fee schedule. This system will run for 6
months and data will likely be collected from your wide cross area of Part
B providers. It's going to make use of the assessments manufactured by the RTI in
conjunction with many other stakeholders that were presented last
year. CMS emphasized that the reason for these assessments were to
identify the many needs in the beneficiaries with differing
clinical conditions and co-morbidities that effect treatment,
including intensity and duration. The research make use of an admission
and discharge assessment to compare treatment and outcomes. The
project will end in Spring 2011.
CMS updated reporting requirements
for therapy services furnished by persons other than licensed
therapy professional, also know as "Incident to". The
updated requirements were effective since July 1st 2010 and required
the identification of the baby supplying the therapy services
being billed. The notice reiterated that is "qualified" to deliver
therapy services and that services which are furnished by others were
not covered and must 't be reported for Medicare payment.
The brand new requirements instruct that
the next information needs to be in the comment field of
the electronic claim (1500 form) or included as a possible attachment in a
paper claim. The mandatory information includes:
Name and therapy level of
performing therapy professional
Name of academic institution
having conferred the degree
Date of graduation
Name and professional degree of
supervising physician/NPP
Do you think that CMS might finally
be decreasing on incident to services We know it's still going
on, utilizing non-therapy trained professionals.
August
15th: CMS completed its Train
the Trainer for MDS 3. 0 and RUGs IV in Vegas on Friday
with little news for therapy. Both main items were that transportation to therapy could not be
counted as preparation time and neither could having the patient
ready for therapy. It's come about due to the information in
the RAI Manual that indicates that enough time an aide spends in
preparing an area to the therapist to deliver individual therapy
may be contained in the minutes just like other set up time once
treatment has begun.
It never ceases to amazes me what
people think up in order to add those minutes. CMS makes it very
clear that SKILLED THERAPY is whatever they is going to be investing in, if
you do not know what that is, you're in trouble.
It was also explained the End of
Therapy (EOT) OMRA Assessment Reference Date (ARD)
should be 1-3
days after last day that therapy would normally be provided in
facility understanding that the ARD needs to be depending on the facilitys
agenda for therapy services (i. e. , treatments are available
Monday-Friday or a week weekly), not based on the therapy
schedule of a particular resident.
It's no direct effect on therapy
because Nursing RUG it is paid from the day after the very last
therapy has become provided. There is not any free ride anymore, that which you do
's what you get purchased, well almost.
The next SNF audio conference on the
3. 0 will likely be on August 24th. Hopefully we'll have a little bit more
of an explanation in the Short Stay Assessment. I'll keep you
posted.
CMS announced that they can
have a special open door forum for many Medicare part b therapy providers on
August 19th to debate Developing Outpatient Therapy Payment
Alternatives (DOTPA)- Data Collection and solicit volunteers to be effective
with one of these assessments
This is a Conference Call
only and will also be held from 2:00 to a few:30. The investigation project known
as DOTPA, for "Developing Outpatient Therapy Payment Alternatives. "
was announced this past year as well as assessments were posted on the RTI
International website CMS as well as data collection contractor, RTI
International, will explain the critical role of providers with this
research. Medicare has become looking for providers to participate
as data collection sites.
This call is intended for many
providers of outpatient therapy (PT), occupational therapy
(OT), and speech language pathology (SLP) who're reimbursed under
Medicare Part B. There exists one assessment which is for those providers
and suppliers except for SNF which has their own specific
assessment.
More info concerning the
project is found at http://optherapy. rti. org as well as on CMS's
website. We are playing the conference and can post
relevant information.
July 2010
July 26th:
The SNF open door forum held on July
22nd didn't tell us a lot! Although each house of congress have passed bills indicating the
repeal in the delay inside the implementation of RUGs IV, CMS continues to be
exploring the hybrid versions before the president actually signs it
into law. The scheduled training calls are already rescheduled for
later in August using the final one developing September 1st, just one single
month prior to the MDS 3. 0 implementation. Speak about eleventh hour
learning!
In working through some situations of
the Short Stay Assessment during our RUG$ to Riche$ seminars, it
appears that, although told the patient that is unexpectedly
discharged before getting a Rehab RUG can certainly still purchase one through
the short stay assessment process, it's going to most likely not occur as
easily as anticipated. This again could make some providers change
policy so that the Rehab RUG level that may have the impact of
pushing for therapy provision on the beginning or over weekend. As usual,
we are going to have to wait and discover.
July 17th:
CMS posted the SNF 2010 Final Rule
for FY 2011. The ultimate
Rule for SNF is around the information website from the Federal Register;
it's going to be published within the register on July 22nd. The most important change
has been doing anticipated wage index and that has experienced a surprise
of the boost in the RUG rates averaging 1. 7 to 1. 9 %. Unlike
multiplication sheet that CMS posted with anticipated rates depending on the
2010 numbers, there is a rise in treatments wage index
containing caused the financial improvement. All the rehab RUGS
have increased over this past year, because of the differ from $116. 93 to
$137. 08 in the Urban therapy index. Nursing wage index decreased
from last year however the Nursing index increased considerably in a few
categories.
The surprising change has been in the
reimbursement for Rehab Low. Due to new ADL
scoring as well as the alternation in the end-splits, RLB features a federal urban
rate of $431. 05, compare that to the present $294. 04. I suppose the
RLB will require the spot with the RMX (almost the same
reimbursement! ! ! !
Lack a restorative program,
well I assume you may now. Do not know the way to set one up which doesn't
get the aides pulled to the floor, we can allow you to there. We'll keep
you posted.
Although do not normally comment
on Home Health Agency Regulations, CMS issued it's
Final Rule concurrently as the SNF there are a handful of noticeable
changes occurring. The documentation guidelines have been updated
and will require justification of continuing services by the
therapist at the 13th and 19th treatment if services are to
continue. There will also be the need from the agency to
differentiate between treatment given by the therapist and the
assistant. Many of the guidelines seem like the updates on the
Medicare part b therapy documentation requirements published in 2007.
July 1st:
CMS revealed the Interim Final
Rule for Medicare part b services on June 25th plus it doesn't look nice! The interim rule which is officially published in the Federal
Register bodes ill for providers and suppliers of Part B therapy
services. The proposed rule, that has an empty comment period till
August 24th proposes a 6. 1% cut within the fee schedule with the
reduction caused by the SGR decrease in 21+% delayed till December
1st over the recent Congressional action. This is simply not all; CMS is
also proposing a "multiple procedure payment reduction" MPPR which
will pay the CPT code while using highest practice expense entirely and
then all the procedures so long as day to the patient will have
their practice component reduced by 50%, the
malpractice and work components are not affected. It really is
anticipated that will result in a further 13% overall reduction
within the CPT code payment on services given that day.
It is not surprising that Secretary
Sibelius was so adamant in her web broadcast to seniors concerned
about the changes to their Medicare Benefits under PPACA (or
Obamacare since it is fondly known. ) In the broadcast, the
secretary was insistent that Medicare beneficiary benefits would not
have the Act and they might retain a bunch of their current
benefits. This is, however, what good is have Part B Medicare
once you aren't able to find a physician or therapist that can manage to take
you! Just my thought and editorial.
Get reading and writing your comments
to CMS. Right after the Final Rule is published we are going to own it
for your requirements over the internet in an edited version that may only
contain information that has relevance to therapy services. If you
can't wait, you are able to download the rule in a very pdf word format from
www. federalregister. gov/inspection. aspx#special
June 2010
June
25th:
Obama signed the
Preservation of Access to Maintain Medicare Beneficiaries and
Pension Relief Act of 2010 today, with a 2. 2% rise in
the PFS valid from June 1st to November 30th 2010. CMS will probably pay
claims for services provided just before June 1st normally; payment
purchased June 1st and later claims which were paid with the
negative rate is going to be reprocessed based on Pinnacle Medicare
Services, one of the MAC contractors.
June
24th: The House has
passed the Senate Amendment to H. R. 3962, the Preservation of Access
to tend Medicare Beneficiaries and Pension Relief Act of 2010. This Act was passed the Senate with unanimous consent on Friday,
June 18. The legislation supplies a couple. 2 percent payment
increase to prospects paid underneath the Medicare physician fee schedule for
a six month period of time ending on Nov 30, 2010. As the word what
reads, it can appear the bill is going to be retroactive time for June
1. The bill will now be delivered to the President's desk to be
signed into law.
June
18th: Congress, specifically
the Senate, did not
agree on a solution on the scheduled decrease in the Fee Schedule,
and, despite CMS's optimism, the 21% decrease went into effect June
1st for services supplied by physicians and therapists. The Senate
version delayed the decrease but only till November 30th, making
further action necessary as soon as the November elections.
June
11th: Congress implementing bill
for PFS and RUGs IV. Congress started work following your Memorial Day recess and convey
action about the looming 21% decline in fee schedule payments. As an ingredient
of the American Jobs and shutting Tax Loopholes Act (HR4213) there is certainly
a proposal to possess a 2. 2% boost in the fee agenda for 2010 and
a 1% increase in 2011 - another stop gap fix, even though it is
extremely welcome. It will also overturn the proposed delay in
implementation of RUG IV. giving CMS the green light due to the
scheduled rollover on October 1st this season.
CMS also released the ultimate updates
on the RAI Manual to the MDS 3. 0 and announced further training
sessions in August to ease the transition. We're
addressing that very topic in your RUG$ to Riche$ workshop coming
in Illinois and Missouri this month and Ohio in July.
June
2nd: We still no interim
rule for SNF PPS around this date. CMS is scheduled to possess its Open
Door meeting tomorrow, so hopefully we're going to use a bit more to visit
on. We'll keep you updated as changes are announced.
May 2010
May
28th: CMS has issued a couple week
hold on tight Part B claims starting June 1st. Till Congress passing a
bill which will stop the decline in the charge schedule, CMS has told
its contractors to hold payment on claims billed for services
starting on June 1st for 15 consecutive days. This may prevent them
the need to adjust claims when the bill is eventually passed, probably
sometime in the near future.
The existing version before Congress
prevents the scheduled decrease from taking effect whilst the flawed
calculation of the sustainable rate of growth is corrected. This bill
would put a moratorium about this reduction for an additional three plus a
half years. At the same time providers can look toward a small
increase, as opposed to the planned 21% reduction.
May
24th: Well, we FINALLY
have news in regards to the adjustments to the SNF PPS system effective October
1st! Today, CMS issued
an update around the progress being made. Were waiting for the
Interim Final Rule that is normally published the final of April to
a sluggish start May, without results, which means this update continues to be long
in coming.
The end result with this update is the fact that
the implementation of the MDS 3. 0 and RUG IV will go on as planned. There's a measure before Congress to offer the requirement of the
delay inside RUG IV implementation repealed and CMS is optimistic
this will occur.
However, if not, CMS will build up a
hybrid RUG III system, that may are the specific new
regulations for concurrent and also the hospital look-back period within
the current 53 RUG system and can retroactively adjust rates. This
system should cause the least disruption to payments for the
providers.
Also within the pipeline from Congress is
a partnership between Congress along with the Physicians to put a
moratorium around the 21% plus decrease in the PFS rates for 3 and a
half years even though the flawed calculation of such rates is addresses. Unless Congress acts NOW, the decrease arrive into effect on June
1st. Lets keep our fingers crossed that Congress realizes the
significance of these two 2 changes.
Keep in mind, keep watching, we'll
post any changes as they occur.
April 2010
April
22nd: Inside the CMS SNF open
door today, the
speakers announced the implementation of RUG IV continues to be
delayed in the healthcare bill passed a few weeks ago by Congress. However, the blueprint is to implement 2 of the production of RUG IV on
October 1st, these being the concurrent therapy provision as well as the
look-back into the hospital stay. They stated actually also
utilizing the leadership to ascertain if this wait full
implementation could be changed. Presently, there is absolutely no grouper to
handle this amendment to RUG IV. Obviously in the tone of the
speakers, they may be hoping this hold will likely be changed and the
transition from RUG III to RUG IV as originally planned.
April
14th: Congress does another
quick fix! Yesterday Congress passed the continued Extension Act which
extended the hold on the implementation from the loss of the fee
diary for Part B. The hold is at place until May 31st. CMS
released the transmittal informing the contractors to produce the
wait claims.
March 2010
March
28th: CMS issues
instructions to keep claims for 14 days after April 1st. CMS has issued instructions to
its contractors to hold all Medicare part b claims for services performed
after April 1st for 14 days. This suggests that CMS believes that
Congress will address the 21%+ reduction in payment for Medicare part b
scheduled to hit on April 1st. Due to the Easter recession,
lawmakers will most likely not address this decrease before it goes
into effect in 34 days time.
March
24th: How a New
HealthCare Bill affects you. Great news! We now have the
exception process back up until the end of the season. Not so good news! We'll
be be subject to the 21% plus decrease in the reimbursement for the
services unless Congress adds the measure to its next round of
bills. Effective April 1st (April Fools Day - boy is that
appropriate) all therapy CPT codes will be decreased in
reimbursement.
The APTA for sure the AOTA and
ASHA operate with Congress to get this changed. However,
health related conditions lobby is strong so all we are able to do is wait and discover. We're receiving targeted at this.
March
12th: In yesterdays CMS
"SNF Open Door Forum" it was announced the RACs have been
informed that they were not to chase the SNF stay whenever they had
denied the qualifying stay in hospital. This was brought
up with a previous open door, and also at that point, the speakers said that
this topic was covered in the present Benefit Manual relating to a
skilled stay.
In addition they announced that they
informed hospitals that they can could not arbitrary change an
"inpatient stay" afterwards. The hospitals happen to be been
informed that it is the physician's responsibility to discover the
appropriate payment system to the stay.
This practice had been cause for
concern due to the focus in the RACs on Appropriateness of DRG
payments. Some hospitals had determined after discharge the
patient may not have qualified for the level billed and thus
made that change.
Exactly why is that vital that you the SNF
Well, the qualifying hospital stay is a technical requirement of
payment in the SNF stay. If your technical requirement just isn't met, then
the complete stay is denied and their isn't appeal rights. This leave
the SNF responsible for the expense of the stay.
March 11th:
Yesterday, the Senate passed a bill
extending the exception process through out the season, freezing
the PFS payments with the 2009 level, thus preventing the 21% plus
decrease until September 30th and re-instating the Geographical
Practice Cost Indices (GPCI) floor at 1. 0 'till the end of year.
The balance now visits your house and
then on to the President for signature before becoming final.
March
4th: Yesterday
Barack obama signed into law, beneath the Extension to Therapy Act,
the extension for the 0% change in the charge schedule and the extension
with the exception process till March 31st. CMS lifted it its hold on
payment of March claims. The exception process is currently available
until the end in the month making retroactive to January 1st. Claims is now submitted with the KX modifier as well as the 2009
guidelines have been in place.
March
3rd: Late the other day
Congress passed the Jobs Bill which contained a Thirty day extension to
the hang on implementing the 21% lowering of the charge Schedule as
well as being a Therapy Caps. What do i mean Well, for the time being,
therapists is still paid on the 2009 levels for that CPT codes
under Part B. However, alternatives Caps, all it implies is the fact that were
still within the caps but there is a wait their implementation and
the exception process is within place and retroactive to January 1st. This stop gap effort will expire on March 31st. In the meantime,
therapists come in limbo. It really is widely anticipated that eventually
there'll be, at the very least, single year extension with the exception
method that will probably be made retrospective to January 1st. So stay
tuned and phone your Representatives and Senators in order to
emphasize exactly what this is doing to the Rehab profession. The
freeze in the decrease in payment keeps the physicians happy for
another month, however, minus the exception process, a lot of
beneficiaries will need problems getting appropriate care. Although outpatient hospital setting is not within the caps, they
would certainly have extreme difficulty in handling the patients who
could possibly be without care.
March
1st: We were in a very
hurry and wait mode a week ago looking forward to Congress some thing
concerning the therapy caps and the reduction in the fee schedule. Unfortunately, politics got in terms and absolutely nothing was done. However, CMS believes that it's going to be addressed soon and issued
instructions for it claims contractors to carry all claims beginning
with March 1st for 10 working days. So that they obviously expect some
action next two weeks. We'll post no matter what for the
website so stay tuned for more.
RAC info: As of this
time, the RACs are nevertheless focusing on DRGs and physician's services.
CERT info: The CERT
contractor issued its National Error Rate Report for November 2009. The mistake rate had increased from 3. 6$ in May 2008 close to 7% in
November. The reason for this is actually the more stringent processes that
was introduced by CMS that they wasn't following. The
variety of denials increased predominantly for DMEs and physician
charges, guess why Illegible signatures. This is transforming into a huge
issue for physicians, and therapists will also be not excluded to the
one. We've got addressed these issues in your latest Newsletter. Follow
this url to access our latest edition. Latest Medicare News and Rules For Therapists
Newsletter
February 2010
February 10th: The APTA
announced yesterday the
Senate released a draft version with the "Jobs Bill" and incorporated into
are provisions addressing the caps as well as the conversion factor. The
proposal is always to extend the exception process first more year and
help it become retroactive to January 1st. Additionally, they propose keeping the
2009 conversion element in place until September 30th. There were
hopes that would get passed now but due to
"climate change" taking place in Washington, all votes are actually
postponed because of this week. In the near future will see no action as it is a
"work week at home" as a result of Presidents Day Holiday. Appears like a
good time to get hold of your representatives and relate your
concerns.
We
are still waiting on Congress to determine if we're going to possess the
exception process extended or otherwise not! There were progresses
the Hill with Senator Baucus indicating that he's drafting a bill
to address the caps along with the exception process as well as other items
that expired January 1st. Meanwhile, CMS states that
providers could support billing until this problem has been
resolved. Well! that work well provided that the exception process is
allowed, otherwise both patients and providers may be having problems.
January 2010
Happy Year
to Everyone.
Well, that of a start to the modern Year
and exactly what a difference each day makes! It seems that the enormous
alterations in Health Care might be delayed somewhat. However, once we
stand, the situation is not looking positive for rehab services. The cap is
back in place as well as the new amount is $1860 per cap, the exception has
expired and we are still scheduled to the 21% decrease in
reimbursement since March 1st. We are able to look at that with perverse
"British Humour" and say, well, no less than the patient is
acquiring "More Bang for his or her Cap Buck". Undoubtedly
sanity will prevail and we'll get each those big problems
resolved.
CMS held their SNF open door on
Thursday the 21st and announced that everything is on schedule for
the MDS 3. 0 and RUG IV implementation on October 1st. They've
published a lot of RAI Manual on their site and also the final
sections ought to be there right at the end in the month.
Current Mood: 
dorky
full