What's New SNF

This week CMS the new MDS 3.0 v1.00.4 along with the updated RAI Manual. The only changes affecting therapy are the addition of the Change of Therapy (COT)OMRA to A0310C and an added section in section O, O0450 that identifies the resumption of therapy as indicated in the EOT-R when therapy is resumed at the same level after a break of 3 to 5 days in treatment. For the updated RAI Manual, there is no directions for the changes proposed in the Interim Final Rule concerning supervision of Students, use of …
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This year we are looking at 3 holiday weekends, Memorial Day, July 4th and Labor day, all of which will meet CMS’s new interpretation of not meeting the level of skilled care. Are you ready? You need to be. In the SNF Open Door Forum on May 12th, the CMS team reviewed the interim final rule and indicated that it presently was not strictly enforcing the 3 day rule for facilities that occasionally provided weekend services, however, come October 1st, the rule will be enforced for whatever reason the patient …
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The Interim Final Rule with comment period for SNF PPS was published in the Federal Register. As with all FRs, we have an open comment opportunity for 60 days, giving everyone the chance to voice their opinion on the proposed changes. Apart from the obvious concern over reimbursement reduction, the changes to the use of group therapy probably are causing most concern. Based on the current guidelines for group, any time you have 2 or more people performing the same or similar activities, it constitutes a group. This can occur …
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CMS published the 2012 Interim Final Rule for SNF and gave the industry a jolt. The proposal includes changes in payment structure that could result in just under a $4 billion reduction in payment, also clarification of the missed 3 days of therapy regulation. Along with that clarification came another OMRA to be completed in conjunction with the EOT OMRA when the patient resumes therapy within 5 days of the EOT. Now for the biggy as we say in the UK, the facility will have to review the patient treatment …
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I have had several people contact me to see if I ever heard back from the CMS SNF Open Door team on the questions I sent them in January about the EOT OMRA when a patient misses days of therapy, and guess what the answer is! NO. The questions were also not answered at the March 17th SNF ODF either. At the March 17th meeting, the topic was brought up and it was acknowledged that this requirement is NOT in the RAI Manual. It was brought up that this requirement …
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Last Thursday, during the SNF Open Door call, the speaker addressed the CMS policy for the EOT OMRA when the patient has missed 3 days of therapy. The result for myself and I’m sure most of the listeners was more confusion. I have an e-mail in to the speaker with definitive questions that I hope will clear the confusion. Here is the non-confused information I got from the call. When a patient misses 3 days of therapy then an EOT OMRA must be completed. The 3 days refer to therapy …
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