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April 2011
April
29th: CMS published the
2012 Interim Final Rule for SNF and gave that is a
a jolt. The
proposal includes alterations in payment structure that may result in
slightly below a $4 billion decline in
payment, also clarification of
the missed Three days of therapy regulation. As well as that
clarification came another OMRA being
carried out addition to
the EOT OMRA if the patient resumes therapy within Five days from the
EOT.
/>Let's focus on the biggy even as we say in the
UK, the ability should assess the patient treatment outside/>from the observation period of course, if it's significantly distinctive from
the RUG level they are being paid then a
Change of Therapy (COT)
OMRA is going to be done to produce the new payment level. This review would be
to
be practiced weekly and will finally stop modifications in treatment
some time and modes of treatment that we believe
happens in some facilities. Documentation is going to be under scrutiny to guide the services being
provided along wit identification
around the POT to support group
treatment.
Also changing will be the optimal
assessment reference dates to eliminate
the "double dipping" of
treatment minutes to create 2 different RUG levels combined with the
variety of grace days which
was reduced to 4 days for many other
compared to the 5-day. (Maybe they finally read my comments about reducing/>those dates that i entered as comment for your Final Rule about 5
in the past).
Group treatment
has been redefined to
produce a group to incorporate 4 patients and, in the calculation of the
RUG, only 25%
of group minutes will probably be counted along with the
current restriction of 25% with the total minutes originating from
group. Good News is that the direct line-of-sight supervision of students
is being eliminated.
And that do we
will need to blame No-one
but ourselves. Each time CMS changes payment structure, we changed
the way we practiced. Using
the STRIVE report, the calculation RUG IV
were developed. The STRIVE report established that there were minimal
use group treatment
with a lot of treatment being individual or
concurrent. The data collected from your new system indicates
dramatic decline in
use of concurrent, but significant boost in
group treatment.
We'll be preparing a more in-depth
overview of the
proposed modifications in the next few days. We also will
be updating our Mastering Medicare Seminar to include modifications
once
the Final Rule is published at the final of July.
Our news is that our new website is/>almost good to go live so we hope you will like it and find it
better to negotiate. This, as
well as another factors may be
why April has been low in updates. While using new website, that
ought to
be resolved, so stay tuned for more.
March 2011
March
29th: Well, March is a
quiet month
for news! Unfortunately, it has been a hectic month for me personally and achieving to update
they have been difficult.
I've had several people send me a email
to find out if I ever heard back in the
CMS SNF Open Door team on the
questions I sent them in January about the EOT OMRA every time a
patient
misses days of therapy, and do you know what the answer then is! NO. The
questions were also not
answered with the March 17th SNF ODF either.
At the March 17th meeting, the niche
was brought up
also it was acknowledged this requirement is NOT
in the RAI Manual. It was described that requirement is at
statute
coupled with been addressed inside the FR in 2010 FY. Checking back,
guess what I found. The reference ended up
being to section 409 from the Code of
Federal Regulations covering extended care services. This section
identifies that skilled therapy
services under Part A SNF have to be
provided at least of 5 days every week. The section procedes to
state
that " an intermittent missed treatment of One or two days won't
compromise the Part A coverage. " and
"most SNFs provide Five days a
week coverage". The interesting facts are that statute has been
in place for many
years and was in place when mentioned last year and
we had been while using the MDS 2. 0. I
really guess my real question is "Why has the
CMS SNF group chose to implement this regulation after the
practicing
MDS 3. 0 and also the publication of the RAI Manual"
Anyhow, seeing non of them probably
check this
out column, we'll probably can't say for sure. So, the most effective that we
could easily get from that audio
cast was that they are implementing it! The modern RAI updates will "probably" address it and it is something
that's
not planning to disappear.
Based on all the information We've
had time to obtain, the information inside the
January section still
applies. My recommendation if it, until you have never provided
services with a weekend, after that your
facility could get away with all the 2
missed days plus Sunday. As most facilities are already
able to give
a services on a weekend, either must be holiday
was occurring through the week, or a patient was at an
observation
period as well as the ARD couldn't be moved, then you might see that this
new interpretation relates to
you.
How do you choose managed Well,
if your patient misses days during the week, in the event
the second treatment
is missed then on that day, the group may need to look at why of course, if
the
patient is visible the following day. Remember, this only applies when
all disciplines are missing treatments. Whether it looks
as when the 3rd
treatment day will be missed, then your EOT OMRA should be
done on Day 3 to
stay in compliance (ARD day 1, 2 or 3 following your last
therapy). Now for the tricky bit, has nursing
been providing any
skilled nursing services: if not, then they had better be addressing the
reason for the missed therapy.
WHY Well, the EOT OMRA has a look
back of 7 days, just like others and creates a nursing RUG
payment
applicable through the next day of the very last therapy. If no skills have
been provided then a MDS
might not be also capable of meeting a competent
amount of care. WOW! Then what
This situation has also
been discussed as
guess what happens hasn't happened; the SNF ABN hasn't been issued as well as the
patient hasn't
been informed of the coverage ending and the
nightmare continues. I not really know how many of you reading this
article
paid attention to the audio conference, but, at this point, someone made
the comment that if not seeing the
individual about the Saturday and
Sunday counts as 2 missed days after which, because something happens
around the Monday so
your patient isn't seen and nursing have not
been providing skilled services, should they have given the patient
the ABN
on the Friday and really should this be performed really should be course. The very first answer were yes, and
then, as we have started to
expect from these meetings, the speaker said that she wasn't meaning
until this carried
out. Well, it sure sounded that way if you ask me.
So now we are, no further forward/>plus more confused than ever before. My recommendation, ensure that
someone can provide a weekend treatment if Friday is missed,
and
essential if Thursday and Friday were missed. It, unless
clearly resolved, will finish up being the RACs favorite new/>issue.
Keep tuned in.
February 2011
February 21st: The Department
of HHS announced
which a
combined action by the HEAT task forces had made arrests in many
areas including Brooklyn, Chicago, Detroit and
Miami. The round
up follows investigation of fraud in billing Medicare services and
identified over $240 million in fraudulent claims.
Unfortunately
Therapy was one of the Medicare benefits that's under
scrutiny with no less than three different schemes. A 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 locate follows closely on the
heels
in the OIG are convinced that identified the 2 counties of Queens
and Kings as 2 of the 20 counties
having massive overutilization of
therapy services. Our latest edition with the e-newsletter contains
our editorial report on these reports. To
gain access to the Medicare part b
report
follow this link as well as the SNF
report
follow this link.
February 5th: The
government's combat the increasing prevalence in Medicare and
Medicaid fraud has brought a fresh turn
which puts a spotlight on PTs in
private practice above other therapy providers! Starting March 25th
2011, additional provisions are
being put in place to screen new
providers and suppliers of Medicare services, as well as existing
providers and suppliers
that are revalidating their Medicare
participation.
The newest regulations outlined within the
Final Rule published February 2nd, authorizes
3 levels of additional
screening determined by assessed risk. Beneath the new rule
CMS requires Medicare contractors to
screen all
initial applications, including applications
for the new practice location, as well as any application
received in response to a revalidation
request. The 3
levels derive from
Limited, Moderate and
Categorical Risk.
Limited risk
includes and others OTs and
SLPs in Private practice, Skilled
Convalescent homes and Rehab Agencies;
the screening
requirements are:
1) verify the provider
or supplier satisfy the Federal regulations
while stating requirements for the provider type ahead of enrollment;
2) conduct
license verifications;
3) Conduct database checks on before enrollment basis to
make certain that providers and suppliers meet
enrollment criteria for
their provider/supplier type.
Moderate risk
includes and others
Physical therapists enrolling as individuals or as
group practices
and comprehensive outpatient rehabilitation facilities.
The
screening includes certain requirements in the list above
PLUS
on-site
visits.
The
High-risk category
includes new HHA and DMEPOS
providers, however! ! ! ! ! ! ! Any
therapist in private practice that
would like to provide DME, orthotics or prosthetics to its patients will
have to meet
the same screening requirements because DMEPOS which
are:
1) All the
requirements for limited and moderate risk level;
/>
2) Submission
of your pair of fingerprints for a national background
check from all of folks who maintain a
5 % 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
people who have a Five percent or
greater direct or indirect
ownership interest in the provider or supplier. This must be done
upon submission of the Medicare
enrollment application and within 30
times of the contractor request.
Just as if this wasn't enough, the rule/>also imposes application fees on institutional providers
and provide 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 known for
long enough that
there was a significant amount of both abuse and fraud being
completed by the availability of Part
B services, now we are all going
to get make payment on cost of a few. This rule follows very
trying to the heels
with the OIG reports indicating over by using both Part B
services in 20 counties in
the usa with Miami/Dade County receiving
special recognition as having 4 times the maximum amount of utilization as opposed to/>National Average.
January 2011
January 31st: Last
Thursday, through the SNF Open Door call,
the speaker addressed the
CMS policy for the EOT OMRA if the patient has missed Three days of
therapy. The
result personally and I'm sure the majority of the listeners
was more confusion. I have an e-mail to the speaker
with
definitive questions that I hope will remove the confusion. Here is
the non-confused information I got through the call.
Whenever a patient misses Three days of
therapy then an EOT OMRA should be completed. The days reference/>therapy overall, not each services if PT misses 72 hours
but another therapy misses only 48 hours prior to the
patient resumes
care then this wouldn't normally apply. If the facility provides 7 day
therapy, then the patient would need
to miss 3 consecutive days, so
as an example. The individual receives no therapy service on Friday,
Saturday and Sunday,
then an EOT has to be done. Now it gets
interesting! Inside regulations because the ARD from the EOT must/>occur, it states that it can be day 1, A few as soon as the last day
that therapy was
provided, which presumably means that Sunday would
become the ARD. So one would presume that once the therapist
determines that
there's no chance to offer at least Quarter-hour of
therapy on that day, the MDS coordinator has to be ready
to fix tomorrow
because ARD in order that they usually are not beyond compliance while using
regulations.
Now
comes the confusion with what
actually defines how many days a week a facility provides therapy. In previous calls, as
well as at conferences, Ellen Berry, the PT
who works best for CMS has stated when you demonstrated a chance
to
give you a services on a Saturday or Sunday, that makes that you simply 6 or 7
day week
department. The speaker on Thursday declared that an informal
provision of therapy won't allow you to a Six or seven
day department. First confusion! Next she begun to provide 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
an illustration of this the
proven fact that their facility provides Monday thru Friday only coverage,
but, due to holidays,
they provided services for the Saturday
and Sunday before so your staff would have the Friday holiday
off. The resultant
answer was that, given that they missed Friday
End of the week, then they should have done a EOT as
the
patient missed Three days, although the patient had received the
therapy required by the POT. Second confusion!
/>Once I have the answers to my
questions Let me post them on this web site along with the meantime,
the
moral with this story appears to be, get A quarter-hour from a therapy done, if it
seems like the
person will miss 3 consecutive days or
never treat on the Saturday or Sunday in order to truly say you/>certainly are a Half a dozen times weekly clinic. Ah Government, and also the interesting
thing is, this insurance policy
isn't written down within the RAI Manual. I will be
presuming that this will likely be remedied within the updates
which are
expected 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 and the other for SNF
Part A Services. The findings
in of such reports was of high
overutilization of services with both abuse and fraud occurring. The
tips for those
two reports would increase scrutiny
of claims submitted and institute changes towards the ways in which payment
for these services
are created.
Whatever they found: For outpatient therapy
services, 20 counties were identified that, in '09, had provided
1)
the very best average Medicare payments per beneficiary and a couple of) had
services that produced a lot more
than $1 million altogether 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
despite the fact that beneficiary characteristics remained generally
unchanged, 2) For
profit SNFs were very likely to bill higher paying
RUGS these days to make money or government SNFs, and three)
Some hadt
questionable billing practices with higher RUGs and long period of
stay (total of 348 of facilities in study).
What does that mean for individuals
MORE Medical Reviews!
Who needs to be concerned
Well, for
OPT,
Miami-Dade was analyzed separately from all others mainly because it has a much
higher using all counties. The other
19 counties included 6
counties in Louisiana, 4 in Texas, 3 in Mississippi, 2 in Indiana, 2
in Nyc, One
in Georgia and another in Florida.
For SNF, large companies had the
highest utilization of high RUG levels,
mainly RU groups, with a
noticeable increase in utilization once they purchased new
facilities.
What are triggers
For
OPT, the use of the
KX modifier both during treatment and also on initial therapy visit,
treatment throughout every season
and also services by multiple
providers; there is also treatment exceeding 8 hours per day. For
SNF, high utilization of
RUG Ultra levels together with over average
period of stay and higher than average ADL scores. The report also
identified
used of ICD-9 codes with V57, care involving utilization of rehab
procedures, increasing 4. 9% by 50 percent a few
years heading their list of
codes.
We'll be creating a review of
both reports and possess them posted
in the next few days.
December 2010
December 24th:
The APTA
sent updated information to its members
about the effect with the MRRP
policy. It indicated that the negative effect with the MPPR is offset
with a
blend of the PPIS survey data and the Medicare Economic
Index rebasing. The notice established that the web impact of
those
changes all combined will be a negative impact of approximately 5%. They
would not differentiate between whether this was
for that 20% or 25%
decrease. Since the APTA predominantly issues information
effecting the non-public practitioner, we're making, a presumption/>that 5% affects PTPP, hence the institutional based practices,
including CORFs (Rehab Agencies) and CORFs could have a negative
impact
somewhat higher as ended up initially indicated determined by
practice patterns, of 6% to 7% from 2010
December 23rd:
CMS issued the
transmittal explaining the MPPR policy. The protection is effective January 1st
for those providers and suppliers of
Part B services, however, the
reduction in the practice expense differs for Therapists in
Private Practice from that of institutional
providers. Beneath the
regulations, "suppliers" of Medicare part b services, i. e. therapists in
private practice, that provide services in
an office or
non-institutional setting are susceptible to a 20% reduction
inside the practice expense (PE) as provided inside the
Physician Payment
and Therapy Relief Act, whereas institutional providers i. e. All the Providers, will dsicover the 25% reduction
inside
the PE area of the billed units as originally announced inside
November Final Rule. The Medicare Economic Index was announced
and
offers a negative 2% rebasing of values for that 2011 Fee Schedule. To learn 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 which includes the provisions identified below. This amendment would not address the
MPPR scheduled for January 1st
2011. Also what's not been released may be the Medicare Economic Index
for 2011. This
might have a 7% to 8% negative impact based on
Rick Gawenda, PT, President of the APTA's Health Administration
Section.
So as there is overall very good news, we still are not aware of
the exact financial influence on Medicare
part b services for 2011.
Would you still claims for just about any
services provided in '09 that
you have not filed For those who have, you
better buy them submitted before December 31st or they will be/>denied. Also, the Patient Protection and Affordable Care Act (PPACA)
instituted a single year time frame to produce claims. Therefore,
effective
January 1st 2011, services is going to be automatically denied which are
much older than 1 calendar year.
/>
In
general, first date for determining the 1-year timely filing
period will be the date of service or From
date about the claim. For
institutional claims that include span dates of service (i. e. , a
From and Through
date for the claim), the Through date for the
claim can be 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
fishing line item From
date is employed for determining the date of service for claims filing
timeliness.
To/>observe the Medicare Learning Network Article follow
this link for SNF
and
this link for Medicare part b Services.
/>
December
10th: WOW! Merry Christmas
from Congress. Congress passed the Medicare and
Medicaid Extension Act providing therapists having a
very welcome 2011
gift. The first time, therapists under Part B determine what to
expect come January 1st 2011.
/>
We now have the extension of the
therapy cap exception process till 2012
We now have
a similar reimbursement
fee schedule as 2010 with continuation of the 2. 2% increase
rather than the forecasted 25. 5%
decrease
The proposed 50% reduction in the
practice expense with 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 have to spend
anymore time or any more in our money creating
the hybrid RUG III software and SNFs need not move through
a
amount of having their claims recalculated and monies returned. Therefore, both CMS and SNFs are now able to focus
on receiving the MDS 3. 0
and RUG IV system to generate sense.
December 1st: Yesterday
the President
signed PPTRA into law, providing to get a continuation of
the actual fee schedule till the end of the year.
The cost of the 1
month extension has taken care of with all the 20% MPPR decrease
effective January 1st
2011. However, over the last weeks in the
present session, the SGR is to be addressed to be able to
be proactive
in connection with scheduled 25% decrease at the time of January 1st. Additionally it is
hoped that included
will be the therapy caps along with the extension of
the exception process. Not sure if we ought to be
holding our breath
on that one! It might be a primary.
CMS issued the Final Rule for the/>Physician's Fee Schedule on November 29th, and today will have to
address the new changes.
November 2010
/>November 19th: Well,
the initial sort of great news
for some time! Yesterday the US Senate passed health related conditions
Payment
and Therapy Relief Act (PPTRA) which extends the 2 main. 2% increase in
the charge schedule over the end
of the year. This act also reduces
the 25% loss of the PE reimbursement to 20% obder modalert
online. The scheduled
reduction in the fee agenda for 2011 of around 25% had not been
addressed.
The
American Medical care Association
is encouraging Congress to deal with the implementation of RUG IV, so
regarding slow up the
disruption that might occur with the payment
system. The home has already passed bills which could implement RUG
IV payments
as of October 1st 2010 as opposed to the current schedule
of 2011. CMS has addressed this of their open
door sessions since they
have to produce a hybrid system that could recalculate the
current payments to a mixture of
RUG III and also the MDS 3. 0. Essentially
which means that there'll be a recalculation of payments and intensely/>likely refunds to Medicare. The price of doing this along with the
disruption it would cause is simply another illustration
of the end results of
the HealthCare legislation which "had to get passed therefore we would then
determine what is
at it".
Additionally they addressed the extending the
exception process for Medicare part b therapy caps as the
impact of the cap
about the residents of Skilled Convalescent homes has the most negative
consequences of Medicare beneficiary groups.
Hopefully. the "lame duck" congress
is certain to get their act together finally each of the campaigning has
ended and
start making sense from what they're doing! !
November 3rd: It's official,
therapists will
be in for the reduction in reimbursement starting January
1st. Yesterday, CMS
published the ultimate Rule for 2011 effecting reimbursement
for Medicare part b
services.
Nice thing about it:
the procedure Cap has increased an astonishing $10 to
1870 per cap,
Not so great news: We still need the caps set up with out exception
process for 2011
unless addressed by Congress. Good News
according to CMS: The cap will go father enabling the
beneficiary to get more
therapy before the cap is met! ! ! !
Not so good news: CMS is
implementing the multiple
procedure reduction policy (MPPR),
Very good news: it's 25% with the practice expense RVU from the fee
schedule, not the
50% initially proposed. CMS indicated that it's got
estimated that will result in a 7% to 9% decrease in payments,/>not the 11% to 13% inside the proposed rule! ! !
Not so great: The MPPR
pertains to
all "always therapy codes" provided by the
provider/supplier towards the beneficiary each day. Consequently for
institutional providers it applies to
therapy services performed
on that day, just like the CCI edits. It is provider specific not
discipline specific, therefore, in
case a blend of PT, OT and SLP
services are supplied on the day that, the priciest code
billed by
one of the disciplines will probably be paid completely while rest of
the claim will probably be be subject to
the MPPR reduction. It also relates to
BID treatments as it's day specific not treatment session or visit.
/>Also in the FR, CMS will continue to
address the variety of reimbursement of therapy Medicare part b services.
/>
October 2010
October 28th: SNF Open Door
Forum held today still
reflected the confusion that is
MDS 3. 0 and RUG IV. Until repealed
by Congress, CMS is continuing to work around the development of the/>hybrid RUG III payment system and established that the grouper to
recalculate the RUG payments must be ready within the
Year. Talk
regarding your tax dollars at the job. The home passed the repeal with this
requirement before the recess
nevertheless the Senate continues to have to vote into it
before it can become official, that is certainly RUG IV
payments are valid
from Oct 1st 2010, not 2011.
The speakers frequently mentioned
"listening to comments" created by
providers and so are taking care of
updating the RAI Manual, to address concerns raised. This new manual
must be
published in Spring 2011.
The next Open Door Forum for the MDS
3. 0 is scheduled for November
9th. Hopefully it'll throw some
light on the use of the EOT OMRA in the event the patient misses visits.
We
could keep you posted.
October 26th: Most people are
awaiting the FR for Part B services to
become published. There is absolutely no indication of
whether the proposed adjustments to the charge schedule will probably be changed
in
the now much awaited publication from the 2011 FR, effective January
1st 2011. To compound the concern, the delay
from the implementation
from the 21% plus reduction in payment that's delayed by Congress is
scheduled to expire on November
30th. Whether this can be
addressed from the "lame duck" session ahead of the Christmas recess
is anybodies guess.
/>
Having only finished our seminars on
Medicare Medicare part b, we were no in a position to deliver a/>positive look for Rehab next year.
October 1st: Well, the MDS 3. 0
is official. At the time
of
today, therapist will work under a new group of regulations in
Skilled Nursing. Rules so new a number of
them still wet ink!
CMS clarified the best way to code create
minutes on September 23rd. The minutes
used on build time,
given by an aide, therapist or therapist assistant might be counted
and included as skilled services.
What CMS clarified was the the
minutes are allocated to the mode of therapy services which is being
prepared for.
individual, concurrent or group.
Therefore if the aide is preparing a region
for the therapist to offer group
therapy, then this minutes wound
be included under the group therapy time.
Congress adjourned soon without
addressing some
of the therapy concerns according to the
expiration in the current fee schedule levels set to alter
on December 1st,
setting up a 21% plus decrease for Medicare part b services. There was no action to mix the 2 bills
addressing the rescinding
of the delay within the implementation of RUG IV till pick up.
September 2010
/>September 3rd: The
special open door for the MDS 3. 0 was definitely the very best information
provided yet. Ellen
Berry, PT, an affiliate of the CMS staff presented
info on the application of the short stay assessment, the beginning
of
therapy (SOT) OMRA and also the end of therapy (EOT) OMRA that will come
into effect October 1st. The
presentation dispelled a few of the
confusion but revealed the significance of finding out how the MDS
grouper will work
knowning that, as a result of reimbursement for a few in the
nursing RUGs, it can be financially therapeutic for
the facility not
to accomplish a brief stay assessment since the payment may be better for the
nursing RUG.
/>
The EOT OMRA is often a mandatory
assessment that must definitely be completed if the resident is staying within
the
Part A stay being skilled by nursing. THE SOT along with the short stay
assessments are voluntary assessments that
this facility team will
decide on you aren't.
We'll be incorporating this
into our Basic Seminar along with
some assessment tools/cheat
sheets for the MDS coordinator and therapy to do business with.
A topic mentioned inside
the Q&A was
regarding the way the grouper would trigger an EOT OMRA when the
resident misses more than 72
hrs of therapy. The question was asked
how playstation 3 be handled, as, influenza season is coming and
residents may
miss some treatment days and also the timing from the EOT,
then carrying out a SOT which technically isn't a
new start care and
therefore might generally not necessitate a whole new eval and POT. The
CMS panel indicated that
they would check into this and provides guidance
at the next ODF.
August 2010
August
29th: Last
weeks special open
door forum for the MDS 3. 0
was mainly focused on the
transitional period from the previous
few events of September as well as the
initial times of October for your patients have been within an
observation
period. The periods in September can be taught in
MDS 2. 0 and the days in October by the MDS
3. 0. Speak about
confusing! ! ! CMS includes a produced several excel files which might be
positioned on the
MDS website for MDS Coordinators to locate the
different days taken into account within the observation period. One of many/>options was only to take the default rate for starters or 2 days and
then submit these. 0 for the
balance. The slides are available plus a
recording in the audioconference is going to be published on their own site.
Unfortunately, some people had a enter connection with the conference
call and lost about 20 minutes of knowledge. When it
was
resolved the Q&A is already in session. The final get in touch with this
series is coming Wednesday so
hopefully some of the questions
about the short stay assessment will probably be clarified.
At the same time,
CMS launched its
demonstration to build up an alternate payment system for the
current Medicare cap and fee schedule. This
system will run for 6
months and data will be collected from your wide cross area of Part
B providers.
It will make use of the assessments developed by the RTI in
conjunction with all kinds of other stakeholders that
have been presented last
year. CMS emphasized that this intent behind these assessments were to
identify the many needs with
the beneficiaries with differing
clinical conditions and co-morbidities that effect treatment,
including intensity and duration. The research use an admission/>and discharge assessment to match treatment and outcomes. The
project can easily in Spring 2011.
CMS updated reporting
requirements
for therapy services furnished by persons besides licensed
therapy professional, also called "Incident to". The
updated requirements were effective
by July 1st 2010 and required
the identification of the people offering the therapy services
being billed. The notice reiterated
who is "qualified" to offer
therapy services and that services which were given by others were
not covered and must
stop reported for Medicare payment.
The modern requirements instruct that
the next information needs to be contained in
the comment field of
the electronic claim (1500 form) or included as an attachment inside a
paper claim. The necessary
information includes:
Name and therapy a higher level
performing therapy professional
Name of academic institution
having
conferred the degree
Date of graduation
Name and professional level of
supervising physician/NPP
Think
that CMS might finally
be coming down on incident to services We know it is going
on, utilizing non-therapy trained
professionals.
August
15th: CMS completed its Train
the Trainer for MDS 3. 0 and RUGs IV in Nevada
on Friday
with little news for therapy. Both the main items were that transportation to therapy can't be
counted as
preparation time and neither could obtaining the patient
ready for therapy. It has occur as a result of information in/>the RAI Manual that suggests that the time an aide spends in
preparing a location for the therapist to offer
individual therapy
can be contained in the minutes as can other build time once
treatment has begun.
It
never ceases to amazes me what
people think up in order to add those minutes. CMS has produced it very/>clear that SKILLED Treatments are what you will be purchasing, if
you do not know what which is, you have
trouble.
It absolutely was also explained that the End of
Therapy (EOT) OMRA Assessment Reference Date (ARD)
has
to be one to three
days after last day that therapy would normally be provided in
facility and that the
ARD needs to be using the facilitys
agenda for therapy services (i. e. , therapy is available
Monday-Friday or 1
week every week), not in line with the therapy
schedule of a particular resident.
It's no direct impact
on therapy
as the Nursing RUG is still paid through the day after the final
therapy may be provided. There
is no free ride anymore, what you do
's what you obtain purchased, well almost.
The next SNF
audio conference around the
3. 0 will likely be on August 24th. Hopefully we will have a little bit more/>of the explanation of the Short Stay Assessment. I'll make you stay
posted.
CMS announced that they may
have
a special open door forum for all those Part B therapy providers on
August 19th to discuss Developing Outpatient Therapy
Payment
Alternatives (DOTPA)- Data Collection and solicit volunteers to be effective
with one of these assessments
This is a gathering
Call
only and will also be held from 2:00 to 3:30. The study project known
as DOTPA, for "Developing Outpatient
Therapy Payment Alternatives. "
was announced last year and a couple assessments were posted for the RTI
International website CMS
as well as data collection contractor, RTI
International, will explain the critical role of providers within this
research. Medicare is
currently actively seeking providers to sign up
as data collection sites.
This call is intended for ALL
providers of
outpatient physiotherapy (PT), occupational therapy
(OT), and speech language pathology (SLP) that are reimbursed under
Medicare Medicare part b. There
is certainly one assessment that is for many providers
and suppliers aside from SNF which has their unique specific
assessment.
More info in regards to the
project can be found at http://optherapy. rti. org and on CMS's
website.
We will be playing the conference and can post
relevant information.
July 2010
July 26th:/>The SNF open door forum held on July
22nd didn't inform us a lot! Although each house of congress have
passed bills indicating the
repeal with the delay inside implementation of RUGs IV, CMS remains
looking at the hybrid versions
until the president actually signs it
into law. The scheduled training calls are already rescheduled for
later in August with
all the final one developing September 1st, just one single
month ahead of the MDS 3. 0 implementation. Discuss very
last minute
learning!
In working through some examples of
the Short Stay Assessment during our RUG$ to Riche$
seminars, it
appears that, although told how the patient who's unexpectedly
discharged before receiving a Rehab RUG can continue to
purchase one through
the short stay assessment process, it'll most likely not occur as
easily as anticipated. This again will
make some providers change
policy to be sure the Rehab RUG level that could contain the impact of
pushing for
therapy provision on the first day or higher weekend. As always,
we'll must wait and find out.
July
17th:
CMS posted the SNF 2010 Final Rule
for FY 2011. The ultimate
Rule for SNF is for the information
website of the Federal Register;
it will be published within the register on July 22nd. The main change
has elevated
the anticipated wage index which has experienced a surprise
of the surge in the RUG rates averaging 1. 7 to
a single. 9 %. Unlike
multiplication sheet that CMS posted with anticipated rates in line with the
2010 numbers, there
was an increase in the procedure wage index
containing caused the financial improvement. All the rehab RUGS
have risen over
last year, thanks to the change from $116. 93 to
$137. 08 in the Urban therapy index. Nursing wage index
decreased
from this past year nevertheless the Nursing index increased considerably in most
categories.
The surprising change has
been doing
reimbursement for Rehab Low. Due to the new ADL
scoring as well as the change in the end-splits,
RLB features a federal urban
rate of $431. 05, compare that to the current $294. 04. I guess the
RLB
will take the place from the RMX (almost the identical
reimbursement! ! ! !
Don't have a restorative
program,
well I assume you are going to now. Do not know how to set one up which doesn't
have
the aides pulled for the floor, we are able to assist you to there. We'll keep
you posted.
/>Although do not normally comment
on Home Health Agency Regulations, CMS issued it's
Final Rule at the same time because
the SNF and there are some noticeable
changes occurring. The documentation guidelines have been updated
and definately will require justification
of continuing services through the
therapist in the 13th and 19th treatment if services will be to
continue. You'll also
have your need through the agency to
differentiate between treatment given by the therapist as well as the
assistant. A
lot of the guidelines could be seen as the updates to the
Part B therapy documentation requirements published in 2007.
July 1st:
CMS revealed the Interim Final
Rule for Part B services on June 25th also it doesn't
look really good! 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 a wide open comment period till
August 24th proposes a
6. 1% cut within the fee schedule with the
reduction caused by the SGR reduction of 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 probably pay the CPT code with the highest practice expense in full and
then other procedures provided
that day towards the patient could have
their practice component reduced by 50%, the
malpractice and work components won't be
affected. It can be
anticipated until this will lead to a further 13% overall reduction
in the CPT code payment
on services so long as day.
It is not surprising that Secretary
Sibelius am adamant in her own
web broadcast to seniors concerned
concerning the changes on their Medicare Benefits under PPACA (or
Obamacare as it's fondly known.
) Throughout the broadcast, the
secretary was insistent that Medicare beneficiary benefits would not
be affected by the Act and
they'd retain a bunch of their current
benefits. This really is, however, what good is have Part B Medicare
once
you aren't able to find a doctor or therapist that could afford to take
you! Just my thought and editorial.
Get reading and writing your comments
to CMS. When the Final Rule is published we'll own it
for
you online in an edited version that will only
contain information which has relevance to therapy services. If you
can't
wait, you'll be able to download the rule inside a pdf word format from
www. federalregister. gov/inspection. aspx#special
/>June 2010
June
25th:
Obama signed the
Preservation of Use of Take care of Medicare Beneficiaries and
Pension Relief
Act of 2010 today, that features a 2. 2% boost in
the PFS valid from June 1st to November 30th
2010. CMS can pay
claims for services provided before June 1st as normal; payment
taken care of June 1st and
later on claims that have been paid with the
negative rate will likely be reprocessed based on Pinnacle Medicare
Services,
among the MAC contractors.
June
24th: The home has
passed the Senate Amendment to H. R. 3962, the
Preservation of Access
to tend to Medicare Beneficiaries and Pension Relief Act of 2010. This Act was passed the Senate
with unanimous consent on Friday,
June 18. The legislation offers a couple. 2 percent payment
increase to those paid within
the Medicare physician fee diary for
a couple of months time frame ending on Nov 30, 2010. As which
reads,
it lets you do appear that this bill will be retroactive to June
1. The bill will now be mailed
to the President's desk to be
signed into law.
June
18th: Congress, specifically
the Senate, didn't
agree on
a solution for the scheduled reduction in the charge Schedule,
and, despite CMS's optimism, the 21% decrease went straight into
effect June
1st for services furnished by physicians and therapists. The Senate
version delayed the decrease only till November 30th,
making
further action necessary after the November elections.
June
11th: Congress focusing on bill
for PFS and RUGs
IV. Congress started work as soon as the Memorial Day recess and provide
action for the looming 21% loss of
fee schedule payments. As part
of the American Jobs and shutting Tax Loopholes Act (HR4213) there is certainly
a proposal
to have a 2. 2% surge in the charge agenda for 2010 and
a 1% surge in 2011 - yet
another stop gap fix, eventhough it is
extremely welcome. It'll likewise overturn the proposed delay in
implementation of RUG IV.
giving CMS saving money light because of its
scheduled rollover on October 1st in 2010.
CMS also released
a final updates
on the RAI Manual for the MDS 3. 0 and announced further training
sessions in August to
try and ease the transition. We're
addressing that very topic in your RUG$ to Riche$ workshop approaching
in Illinois and
Missouri this month and Ohio in July.
June
2nd: We still need no interim
rule for SNF PPS
as of this date. CMS is scheduled to have its Open
Door meeting tomorrow, so hopefully we are going to
have a a bit more to look
on. We are going to keep you updated as changes are announced.
/>
May 2010
May
28th: CMS has issued a couple week
hold on Medicare part b claims starting
June 1st. Awaiting Congress passing a
bill that can stop the reduction in the fee schedule, CMS has told
its
contractors to carry payment on claims billed for services
starting on June 1st for 15 consecutive days. This may prevent
them
having to adjust claims in the event 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 from the sustainable
growth rate is corrected. This bill
would put a moratorium on this reduction for an additional three as well as
a
half years. In the meantime providers look toward hook
increase, instead of the planned 21% reduction.
May/>24th: Well, we FINALLY
have news concerning the adjustments to the SNF PPS system effective October
1st! Today, CMS issued/>an update for the progress being made. We're waiting for the
Interim Final Rule which can be normally published the
finish of April to
a sluggish start May, without results, which means this update continues to be long
in coming.
The result on this update is
the implementation of the MDS 3. 0 and RUG IV go on
as planned. You will find there's measure before Congress to achieve the dependence on the
delay inside the RUG IV
implementation repealed and CMS is optimistic
that this will occur.
However, otherwise, CMS will build up a
hybrid
RUG III system, that may add the specific new
regulations for concurrent and also the hospital look-back period within
the
present 53 RUG system and definately will retroactively adjust rates. This
system should increase the risk for least disruption to
payments to the
providers.
Also inside the pipeline from Congress is
a contract between Congress and also the
Physicians to locate a
moratorium on the 21% plus decline in the PFS rates for 3 as well as a/>half years while the flawed calculation of those rates is addresses. Unless Congress acts NOW, the decrease arrive into influence
on June
1st. Lets keep our fingers crossed that Congress realizes the
need for both these 2 changes.
/>As always, keep watching, we'll
post any changes because they occur.
April 2010
April
22nd:
Inside CMS SNF open
door today, the
speakers announced the implementation of RUG IV continues to be
delayed inside healthcare
bill passed recently by Congress. However, the plan is to implement a couple of the provision of RUG IV on/>October 1st, these being the concurrent therapy provision as well as the
look-back in to the hospital stay. They stated
they are also
working together with the leadership to ascertain if this hold on tight full
implementation can be changed.
Presently, there is no grouper to
handle this amendment to RUG IV. Obviously from the tone from the
speakers, they're
hoping that hold will probably be changed as well as the
transition from RUG III to RUG IV as originally
planned.
April
14th: Congress does another
magic pill! Yesterday Congress passed the continued Extension Act which
extended the
hang on the implementation with the loss of the charge
schedule for Medicare part b. The hold is at place
until May 31st. CMS
released the transmittal informing the contractors release a the
hold on 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 support all Medicare part b claims for services performed
after April 1st for Fourteen days. This means
that that CMS believes that
Congress will address the 21%+ reduction in payment for Medicare part b
scheduled to hit
on April 1st. As a result of Easter recession,
lawmakers will probably not address this decrease prior to it going/>into effect in 34 days time.
March
24th: The way the New
HealthCare Bill affects you. Good News!
We have the
exception process back till the end of the season. Bad News! We are going to
be susceptible
to the 21% plus decrease in the reimbursement for
services unless Congress adds the measure to the next round of/>bills. Effective April 1st (April Fools Day - boy is the fact that
appropriate) all therapy CPT codes will probably
be decreased in
reimbursement.
The APTA and I'm sure the AOTA and
ASHA work with Congress to try
to get this changed. However,
the Physician lobby is strong so all we can easily do is wait and discover.
We're receiving targeted at this.
March
12th: In yesterdays CMS
"SNF Open Door Forum" it was announced that
this RACs had been
informed that they are to never pursue the SNF stay once they had
denied the qualifying
stay in hospital. This ended up brought
up at the previous open door, and also at the period, the speakers
said that
this topic was covered in the current Benefit Manual in relation to a
skilled stay.
Additionally,
they announced they had
informed hospitals which they could not arbitrary change an
"inpatient stay" afterwards. The hospitals are actually
already been
informed that it's the physician's responsibility to determine the
appropriate payment system for the stay.
This
practice have been grounds for
concern due to focus in the RACs on Appropriateness of DRG
payments. Some hospitals had
determined after discharge the
patient may possibly not have qualified for the level billed and therefore
made that change.
/>
Exactly why is the fact that vital that you the SNF
Well, the qualifying stay in hospital is often
a technical desire for
payment in the SNF stay. In case a technical requirement is not met, then
the whole
stay is denied along with their isn't appeal rights. This leave
the SNF to blame for the price of the
stay.
March 11th:
Yesterday, the Senate passed a bill
extending the exception process through out the entire year,
freezing
the PFS payments on 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 bill now visits
the home and
then on on the President for signature before becoming final.
March
4th: Yesterday
Barack obama
signed into law, under the Extension to Therapy Act,
the extension for the 0% alternation in the charge schedule and
the extension
from the exception process till March 31st. CMS lifted it its hold on tight
payment of March claims.
The exception process is now in position
'till the end in the month and made retroactive to January 1st. Claims
can be submitted with all the KX modifier and the 2009
guidelines are in place.
March
3rd: Late
the other day
Congress passed the Jobs Bill which contained a One month extension to
the hold on tight implementing
the 21% reduction in the Fee Schedule as
well being a Therapy Caps. What does that mean Well, for the
present time,
therapists is still paid at the 2009 levels for the CPT codes
under Part B. However, as for
the Caps, all this means is we have been
still within the caps there is however a hold on tight
their implementation and
the exception process is at place and retroactive to January 1st. This stop gap effort will expire
on March 31st. In the meantime,
therapists will be in limbo. It really is widely anticipated that eventually
you will
have, at a minimum, a 1 year extension in the exception
process that will probably be made retrospective to January
1st. So stay
tuned and contact your Representatives and Senators to be able to
emphasize just what this really is
doing on the Rehab profession. The
freeze inside the reduction in payment keeps the physicians happy for
another month, however,
with no exception process, plenty of
beneficiaries will need problems getting appropriate care. Although outpatient hospital setting is not underneath
the caps, they
would certainly have extreme difficulty in handling the patients who
might be without care.
March/>1st: Well we were in a very
hurry and wait mode yesterday expecting Congress some thing
regarding the therapy caps
along with the reduction in the fee schedule. Unfortunately, politics got in terms and nothing was done. However, CMS believes
that it'll be addressed soon and issued
instructions into it claims contractors to support all claims beginning
with March 1st
for 10 business days. So they really obviously expect some
action next fourteen days. We'll post no matter what about
the
website so keep tuned in.
RAC info: As of this
time, the RACs are still 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 three. 6$ in May 2008 to over 7% in
November. The reason behind this
is the tighter processes that
was introduced by CMS that they can was not following. The
quantity of denials increased
predominantly for DMEs and physician
charges, guess why Illegible signatures. This can be learning to be a huge
issue for
physicians, and therapists may also be not excluded with the
one. We've addressed these complaints inside our latest Newsletter. Follow/>this hyperlink 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 from the "Jobs Bill" and incorporated into/>are provisions addressing the caps and the conversion factor. The
proposal is always to extend the exception process for just
one more year and
make it retroactive to January 1st. Additionally, they propose keeping the
2009 conversion take into account
place until September 30th. There were
hopes until this would get passed this week but as a result of
"climate
change" happening in Washington, all votes have been
postponed because of this week. In a few days might find no
action as it is a
"work week at home" because of the Presidents Day Holiday. Sounds like a
good time
and energy to obtain your representatives and relate your
concerns.
We
still are waiting on Congress to see if
we intend to possess the
exception process extended or not! There were progresses
the Hill with Senator Baucus indicating that
he's drafting a bill
to deal with the caps as well as the exception process and also other items
that
expired January 1st. For the time being, CMS has stated that
providers could endure billing until this problem may be/>resolved. Well! that work well providing the exception process is
allowed, otherwise both patients and providers could be in trouble.
January 2010
Happy Year
to Everyone.
Well, exactly what a start to the modern Year
and that of
a difference every day makes! It would appear that the massive
alterations in Medical care might be delayed somewhat. However,
as we
stand, things are not looking good for rehab services. The cap is
back in place and the new
amount is $1860 per cap, the exception has
expired so we remain scheduled for that 21% reduction in
reimbursement since
March 1st. We can easily look at that with perverse
"British Humour" and say, well, a minimum of the sufferer
is
getting "More Bang for their Cap Buck". Without a doubt
sanity will prevail and we will get both those
big problems
resolved.
CMS held their SNF open door on
Thursday the 21st and announced that things are all
on schedule for
the MDS 3. 0 and RUG IV implementation on October 1st. They have
published more of the
RAI Manual online as well as the final
sections should be there in the end of the month.
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