RCS-1 Shelved, CMS Posts SNF Fiscal Year 2019 Proposed Rule

RCS-1 Shelved, CMS Posts SNF Fiscal Year 2019 Proposed Rule

May 2018

RCS-1 Shelved

Issued May 4, 2018

On April 27th, 2018, CMS announced that the Resident Classification System, Version 1 (RCS-1), which was to replace the existing PPS RUG-IV payment methodology, released a new proposed rule titled: Medicare Program: Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities (SNF) Proposed Rule for FY 2019, SNF Value-Based Purchasing Program, and SNF Quality Reporting Program. The document will be published in the Federal Register on May 5th, 2018. Although the delivery of care may change, therapy services will continue to be a critical aspect of skilled nursing facility (SNF) care the new Patient-Driven Payment Model (PDPM). Independence Rehab will continue to put people first to achieve quality outcomes for residents and desirable financial results for you.

Some of the Proposed Rule Highlights are:

CMS estimates FY 2019 aggregate increase of $850 million in Medicare payments to SNFs.New updates to policies, adjustments to the scoring methodology and Extraordinary Circumstances Exception (ECE) policy.A new payment system to replace the current system of the Resource Utilization Groups IV (RUGs IV).The proposed date for implementation of this system is October 1, 2019.

The Proposed Rule Details are:

CMS is proposing payment reform for SNF to replace the existing PPS RUG-IV payment methodology which is currently scheduled to begin in October of next year with the Patient-Driven Payment Model (PDPM). CMS proposes this new system to continue to move Medicare toward a more value-based, unified post-acute care payment system. Highlights of the proposed changes as compared with the current payment system include: PDPM will be driven by a patient’s characteristics (e.g. medical conditions and function) versus the volume of services (i.e. therapy minutes). There are five case-mix adjusted payment components rather than four. They include:

  1. Therapy (PT)
  2. Occupational Therapy (OT)
  3. Speech Language Pathology (SLP)
  4. Nursing and Non-Therapy Ancillary Services (NTAs) such as drugs, lab services, respiratory therapy and medical supplies.
  5. This includes 16 case-mix groups each for PT and OT; 12 for SLP, 25 for Nursing and 6 for NTAs

The proposed changes will include changes to:

Concurrent and Group TherapyMDS Discharge Assessment.Per Diem Adjustment in ReimbursementThere will be a 2% Decrease in the PT and OT Case-Mix ComponentThe ADL Data CollectionMDS Reporting

With all these significant changes on the horizon, Independence Rehab remains committed to adapting to ensure our clients and our patients receive the quality care they deserve, our employees have the proper support and training, and our clients have a trusted partner to successfully navigate through this together. Please contact us to learn more about how we can help you prepare for PDPM. The deadline for comment submission is 5 p.m. on June 26, 2018. Release of the SNF PPS final rule is anticipated for August 2018.
To submit your own comment, click here.