CMS publishes Interim Final Rule for SNF

CMS published the Interim Final Rule for Fiscal Year 2014, which becomes effective Oct 1st, 2013. A pleasant surprise is that there will be a small increase in payment of 1.4%.

CMS is proposing to add an item to the Minimum Data Set (MDS) to record the number of distinct calendar days of therapy provided by all the rehabilitation disciplines to a beneficiary over the seven-day look-back period.  Furthermore, CMS is clarifying that the qualifying condition for the Medium Rehab (RM) Category requires 5 distinct calendar days of therapy.  Similarly, CMS is clarifying that the qualifying condition for the Low Rehab (RL) Category would be clarified to require 3 distinct calendar days.

Currently, the number of days for each therapy disciplines reported on the MDS is summed without regard to the number of separate and unique days per week on which the patient receives therapy services across all rehabilitation disciplines.  This results in some patients receiving higher SNF payments for an RM or RL Resource Utilization Group (RUG) when the patient actually does not meet the qualifying conditions for that RUG.   The proposed addition to the MDS ensures SNFs are paid accurately for their patients.

We are aware that there have been some facilities billing Rehab medium because the software was unable to distinguish different days. This is probably the last of the loopholes that CMS has provided a fix for, at least for now. The update to the RAI manual should be posted sometime next week

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