snf guide to fy2015 pps final rule & october 1st rai user's manual updates

FY 2015 Final Rule

HARMONY UNIVERSITYThe Provider Unit of

Harmony Healthcare International, Inc. (HHI)Presented by:

Melissa Fox, OTR/LRegional Consultant

FY 2015 Final Rule

The Final Rule will be implemented on October 1, 2014

Medicare payment rates for skilled nursing facilities (SNFs) with a 2% increase FY 2015

2.5% market basket increase, reduced by the 0.5% point multifactor productivity adjustment required by law

Change in the market basket index did not exceed the 0.5 percentage point threshold, therefore payment rates for FY 2015 do not include a forecast error adjustment

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FY 2015 Final RuleUrban vs. Rural Status

CMS will adopt the most recent Office of Management and Budget (OMB) statistical area delineations to identify a facility’s Urban or Rural status

Includes a one year transition with a blended wage index for all providers for FY 2015

Some nursing homes have gone from Rural to Urban categories and vice-versa

One-year blended system, in which reimbursements will be based on a 50/50 split of a SNF’s former and new designation


FY 2015 Final RuleCOT

COT OMRA PolicyThe Final Rule for FY 2015 revises this existing COT OMRA policy to permit providers to complete a COT OMRA for a patient that was previously classified into a RUG-IV therapy group but is currently in a non-therapy RUG

FY 2015 Transition Memo to be released


FY 2015 Final RuleTherapy Payment Options

The Final Rule includes a discussion of the SNF therapy payment research currently contracted with Acumen, LLC and the Brookings Institution to identify potential alternatives to the existing methodology used to pay for therapy services received under the SNF PPS

A report outlining the most promising and viable options that CMS plans to pursue is available at the CMS website at:

http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/SNFPPS/therapyresearch.html





CMS highlighted a trend in the Final Rule indicating that “the number of therapy minutes provided to SNF residents within certain therapy RUG categories is, in fact, clustered around the minimum thresholds for a given therapy RUG category.”



“Given the comments highlighting the lack of medical evidence related to the appropriate amount of therapy in a given situation, it is all the more concerning that practice patterns would appear to be as homogenized as the data would suggest.”



CMS also responded to a comment received in response to the proposed rule “which highlighted potential explanatory factors for the observed trends, such as internal pressure within SNFs that would override clinical judgment, we find these potential explanatory factors troubling and entirely inconsistent with the intended use of the SNF benefit. Specifically, the minimum therapy minute thresholds for each therapy RUG category are certainly not intended as ceilings or targets for therapy provision.”



“Therefore, services which are not specifically tailored to meet the individualized needs and goals of the resident, based on the resident’s condition and the evaluation and judgment of the resident’s clinicians, may not meet this aspect of the definition for covered SNF care, and we believe that internal provider rules should not seek to circumvent the Medicare statute, regulations and policies, or the professional judgment of clinicians.”


FY 2015 Final Rule

“As discussed in Chapter 8, Section 30 of the Medicare Benefit Policy Manual (Pub. 100-02), to be covered, the services provided to a SNF resident must be “reasonable and necessary for the treatment of a patient’s illness or injury, that is, are consistent with the nature and severity of the individual’s illness or injury, the individual’s particular medical needs, and accepted standards of medical practice (emphasis added).”


RAI Manual Updates

The RAI User’s Manual Version 1.12 is scheduled to be posted to CMS’ Nursing Home Quality Initiatives website:http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/MDS30RAIManual.html on or about September 5, 2014


http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/MDS30RAIManual.html







QIO Changes

Copyright © 2014 All Rights Reserved 12Harmony Healthcare International, Inc.

Livanta, LLC

The geographic Area 1 and Area 5 were awarded to Livanta, LLCArea 1: Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Puerto Rico, Rhode Island, Vermont, Virgin Islands

Area 5: Alaska, Arizona, California, Hawaii, Idaho, Nevada, Oregon, Washington


KePRO

The contract awards for Areas 2, 3 and 4 were awarded to KePROArea 2: District of Columbia, Delaware, Florida, Georgia, Maryland, North Carolina, South Carolina, Virginia, West Virginia

Area 3: Alabama, Arkansas, Colorado, Kentucky, Louisiana, Mississippi, Montana, North Dakota, New Mexico, Oklahoma, South Dakota, Tennessee, Texas, Utah, Wyoming

Area 4: Iowa, Illinois, Indiana, Kansas, Michigan, Minnesota, Missouri, Nebraska, Ohio, Wisconsin


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Memorandum of Agreement (MOA)

Read the entire MOA

On page 1, please enter your provider name twice on page 1 where indicated

On page 7, complete all blank lines including signing your name electronically or manually. If you are agreeing to sign electronically, just type in your name. If you wish to sign manually, of course, you will first need to download the document.

On page 8, designate an individual from your organization who will serve as the official QIO Liaison

Send a completed and signed copy of the MOA by email to QIO

Copyright © 2014 All Rights Reserved

Memorandum of Agreement (MOA)

Send MOA within 30 days of your receipt of this document to avoid having your organization be out of compliance with Federal Law. An organization that does not submit a signed copy of the MOA will be reported to the Centers for Medicare & Medicaid Services (CMS) as violating the Conditions of Participation in the Medicare program.


Key Points

Beginning August 1, 2014

Update all contact references, address books, and beneficiary forms to reflect contact information for specific QIO and Areas

Remind facilities to return their MAO

If appeals are not responded to have beneficiary call 1-800-MEDICARE


Questions/Answers

Harmony Healthcare International1 (800) 530 – [email protected]

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Register online http://info.harmony-healthcare.com/harmony2014

or by phone (978) 887-8919 ext. 13

Register Online

http://info.harmony-healthcare.com/harmony2014

http://info.harmony-healthcare.com/symposium2014/registration

snf guide to fy2015 pps final rule & october 1st rai user's manual updates

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