New Hospital-Acquired Condition (HAC) Reduction Program: What does it mean for my SNF?

As part of the new HAC Reduction program, beginning in FY 2015 hospitals that rank in the lowest quartile for medical errors or serious infections, that patients contract while in the hospital, will be paid 99 percent of what they otherwise would have been paid under the IPPS. This rule finalizes the criteria to rank hospitals with a high rate of hospital-acquired conditions.

If past trends continue,  we can expect some hospitals to choose not to bill Medicare or anyone else when one of these conditions presents itself.  Unfortunately, when they don't bill Medicare, there is no qualifying stay, so there is no SNF benefit available.  

FY14 SNF & CB FInal Rule Published

Press Release: 
 CMS finalizes fiscal year 2014 payment and policy changes for Medicare skilled nursing facilities

Overview

On July 31, 2013, the Centers for Medicare & Medicaid Services (CMS) issued a final rule [CMS-1446-F] outlining fiscal year (FY) 2014 Medicare payment rates for skilled nursing facilities (SNFs). The major provisions of the final rule are summarized below.

Changes to payment rates under the SNF Prospective Payment System (PPS) for FY 2014

Based on the changes contained within this final rule, CMS estimates that aggregate payments to SNFs will increase by $470 million, or 1.3 percent, for FY 2014 relative to payments in FY 2013. This estimated increase is attributable to the 2.3 percent market basket increase, reduced by the 0.5 percentage point forecast error correction (explained below) and further reduced by the 0.5 percentage point multifactor productivity adjustment required by law.

The FY 2014 SNF PPS payment rates and policies will be effective on October 1, 2013.

Revise and rebase the market basket

The Medicare statute requires CMS to establish a SNF market basket index that reflects changes over time in the prices of an appropriate mix of goods and services included in covered SNF services. CMS has developed a SNF market basket index that encompasses the most commonly used cost categories for SNF routine services, ancillary services, and capital-related expenses. The SNF market basket index is a factor used to update the SNF PPS payments on an annual basis. CMS is rebasing and revising the SNF market basket for FY 2014 and subsequent years to reflect more recent data. The current SNF market basket reflects data from FY 2004 and CMS is updating the SNF market basket using data from FY 2010. In addition, CMS will make changes to the components of the SNF market basket index by adding five new cost categories and dividing the existing Nonmedical Professional Fees cost category into two separate categories, labor-related and non labor-related Nonmedical Professional Fees (for a total of 29 cost categories), and revising several price proxies, including the price proxy for the Wages and Salaries and Employee Benefit cost component.

Reporting of distinct therapy days

To ensure accuracy in case-mix assignment and payment, CMS is adding 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. CMS is clarifying that the qualifying condition for the Medium Rehab (RM) Category requires five distinct calendar days of therapy. Similarly, CMS is clarifying that the qualifying condition for the Low Rehab (RL) Category requires three distinct calendar days. Currently, the number of days for each therapy discipline reported on the MDS is summed without regard to the number of separate and unique days per week during which the patient receives therapy services across all rehabilitation disciplines. This results in some residents qualifying inappropriately for an RM or RL Resource Utilization Group (RUG). The addition to the MDS ensures SNFs are paid accurately for the therapy services they provide to their residents.

Forecast error correction

A forecast error correction is applied when the difference between the actual and projected market basket percentage change for a given year (the most recent available FY for which there is final data) exceeds the 0.5 percentage point threshold. While CMS normally reports the forecast error to one significant digit, such reporting makes it difficult to determine if the threshold has been exceeded in those instances where the difference between the projected and actual market basket percentage change rounds to 0.5 percentage point. Therefore, only in those instances where the difference between the projected and actual market basket percentage change rounds to 0.5 percentage point at one significant digit, CMS will report the difference to the second significant digit to determine if the threshold has been exceeded. The most recent available FY for which there is final data is FY 2012. For FY 2012, the projected market basket percentage change exceeded the actual market basket percentage change by 0.51 percentage point. As the projected market basket percentage change exceeded the actual market basket percentage change by an amount greater than the 0.5 percentage point threshold, the FY 2014 market basket update will include a downward adjustment of 0.5 percentage point.

A link to the final rule, which will be published in the Federal Register on August 6, 2013, is available at:https://www.federalregister.gov/public-inspection.

For further information about the SNF PPS, please visit http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/SNFPPS/index.html.

New CMS MDS Training video is now posted to YouTube

From the SNF ODF Website (See Resources on my website):

‘Discharge Assessments and the Use of Dashes’ video is activated on the DHHS YouTube site;  Access to this video is available on the MDS 3.0 Training page  in the Related Links section or at:  http://youtu.be/Qkn22jv2HSY. Discharge Assessments and the Use of Dashes are addressed in our new MDS 3.0 Provider Update Training Series. This training series is the first web-based training offered in 2013 to providers addressing post-acute care topics. Video No. 1 covers MDS 3.0 updates for the Nursing Home setting. It includes a CMS Introduction, a panel presentation explaining what the MDS 3.0 RAI Manual and the MDS 3.0 Assessment Instrument are, and includes two training topics. The first training topic focuses on our relatively new discharge assessments, and the second topic explains how to properly code with dashes. 

From Judy:  This is a 30 minute video, the first 11 minutes cover general intro comments about what the MDS is.   While this portion is two speakers reading from a teleprompter,  the first portion is a great intro to brand new LTC folks about what the RAI process is.  

Then they cover two topics:  Discharge assessments  and Dashes. This is not a video on 'the use of dashes on a discharge assessment.  They cover the two separately.    I found it helpful to go to the YouTube link, open the 'transcript" button, which allows me to jump around in the video by clicking on specific parts of the transcript.

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New Draft of the Oct 1,2013 MDS forms posted

MDS 3.0 Technical Information

What's New -

June 03, 2013

A new version (v1.11.1) of the MDS item sets was posted. This version is scheduled to become effective October 1, 2013 in conjunction with the new version of the data specs (v1.13.1). The item sets should also be considered provisional or draft and subject to change until final item sets are published.

MDS 3.0 Item Subsets V1.11.1 for the October 1, 2013 Release [ZIP, 8MB]

From Judy:  This one adds the line from the FY14 Proposed Final Rule  to list distinct calendar days of therapy for the new Rehab Medium and Low rules.  There are other changes that were in the earlier draft, but this is the latest one.  

Virginia Providers: Virginia revises Section Q fax referral form

The Department of Medical Assistance Services (DMAS) announced on Tuesday this week that the revised MDS 3.0 Section Q Referral Fax Transmittal Notification Tracking form has been uploaded to the DMAS website.  The form, DMAS-P261, and instructions can be located on the resources section of my website.
 
To assist the Nursing Facilities, Local Contact Agencies, and the Transition Coordination Providers with the Section Q referral process, the revised workflow is included with step by step instructions on the completion of the DMAS-P261 form.

A 30-minute Section Q training WebEx has also been uploaded to the DMAS website to provide further guidance for nursing facilities and local contact agencies.  

Contact Amy Burkett, State Section Q Coordinator at 804.786.0568 or via email atamy.burkett@dmas.virginia.gov with any questions about the MDS Section Q process.

2013 Medicare Trust Fund Report released Friday

To read report:  http://www.cms.gov/Research-Statistics-Data-and-Systems/Statistics-Trends-and-Reports/ReportsTrustFunds/Downloads/TR2013.pdf

"The trust fund that finances Medicare's hospital insurance coverage will remain solvent until 2026, two years beyond what was projected in last year's report,"

The Washington Post notes that the trustees "also credit lower costs and use rates in 'most ... service categories — especially skilled nursing facilities' — a development that most economists believe is in part due to the recent recession but also to more fundamental efforts to reduce costs throughout the health care industry."

All RACs now have SNF issues for review posted: In addition to MMR

All four RACs have, since May 2013, added SNF specific issues for review to their "current issues"  list on their websites.  You can find your RAC, then go to the specific website to see the issues,  by clicking:  http://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/recovery-audit-program/index.html?redirect=/rac

Or just google  "CMS RAC"  and click on the cms.gov links.