CMS Issues SNF PPS Final Rule for FY 2012 [08-02-11]

Filed under: Industry Updates — Editor @ 2:42 pm

On July 29, 2011 the Centers for Medicare and Medicaid Services (CMS) released the Skilled Nursing Facility Prospective Payment System (SNF PPS) final rule for Fiscal Year (FY) 2012. The final rule will be published on August 8, 2011 and will be effective October 1, 2011.  The final rule had very few changes from the proposed rule.  A summary of the final rule is provided below:

Payment reduction: The rule contains an 11.1% reduction in payments to skilled nursing facilities for FY 2012. This reduction is due to a recalibration of the case-mix indexes to account for increases in payment levels that were not anticipated by CMS after the revision of policies regarding RUG-IV, specifically the allocation of concurrent therapy minutes in the FY 2010 final rule

Allocation and definition of group therapy minutes: CMS has defined group therapy as therapy provided simultaneously to 4 patients who are performing similar therapy activities. For therapists treating patients in a group setting, the full time spent by the therapist with these patients would be divided by 4 (the number of patients that comprise a group).

Student supervision policies: CMS has discontinued the policy announced in the FY 2000 final rule’s preamble requiring line-of-sight supervision of therapy students in SNF. Effective October 1, 2011, as with other inpatient settings, each SNF will determine for itself the appropriate manner of supervision of therapy students consistent with state and local laws and practice standards. CMS stated the student is viewed as an extension of the therapist; therefore, the policies regarding individual, concurrent, and group therapy as articulated in the RAI manual are still applicable.

Implementation of the Change of Therapy (COT) OMRAs: CMS will require a new assessment, the COT OMRA, to be completed every 7 calendar days to update current therapy provided to the patient, regardless of whether the patient has had a significant change in condition. Seven days after the previous Assessment Reference Date (ARD), the facility is to review the resident’s records and determine if the level of therapy has changed, such that the resident would be classified in a new rehab category. The COT can be used to report either an increase or decrease in the level of therapy received.

Clarification of End of Therapy (EOT) OMRAs: EOT OMRA must be completed if a patient goes 3 consecutive days without treatment regardless of how often the facility offers therapy. An End of Therapy Resumption (EOT-R) OMRA will be available beginning October 1, 2011, for use when the therapy resumes within 5 days.

The proposed changes to the MDS 3.0 assessment windows were also finalized as proposed:

5 day* = days 1-5, with grace days 6-8
14 day = days 13-14, with grace days 15-18
30 day = days 27-29, with grace days 30-33
60 day = days 57-59, with grace days 60-63
90 day = days 87-89, with grace days 90-93

*(Changes would also apply to Readmission/Return Assessment)

The Centers for Medicare & Medicaid Services (CMS) will host a National Provider Call on “Skilled Nursing Facility (SNF) Prospective Payment System (PPS) FY2012 Policy Changes Relating to the Minimum Data Set (MDS) 3.0.” on August 23, 2011 from 1:30-3:30pm EST. For more information and registration, please click HERE.

Click here to read the final rule.  2011-19544_PI

This summary courtesy of NARA.

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