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Date ArticleType
7/31/2017 Payment/Reimbursement
Impact Analysis for CMS Proposed Revisions to Part A Payments

By: Nancy Hublar and Landon Hackett, Blue & Co.

CMS has released an advanced notice of proposed rulemaking (ANPRM) to solicit comments on potential options for revising aspects of the existing skilled nursing (SNF) prospective payment system payment methodology. CMS is seeking comments on replacing the SNF PPS existing case-mix classification model with the Resource Utilization Groups, Version I (RCS-I). Where the current SNF PPS payment system, Resource Utilization Group (RUG) – IV, consist of two case-mix adjusted components: therapy and nursing; the proposed RCS-I would create four case-mix adjusted components. CMS is expanding the case-mix components to achieve a more resident-centered case-mix adjustment.

Below are listed the proposed revised case-mix adjusted components that will revise the base rate structure.

Four case-mix adjusted components
• Physical Therapy/Occupational Therapy
• Speech-Language Pathology
• Nursing
• Non-Therapy Ancillary

Non-case-mix component
• No proposed changes

In addition to RCS-I, CMS is proposing the following:
• Regulatory reduction under the SNF PPS model
• Decreasing the number of required assessments

Blue & Co. has also prepared a summary of highlights of the proposed ANPRM to assist you in preparation for possible comments to CMS. The American Health Care Association has estimated the possible implementation date as October 1, 2018. While reviewing the ANPRM, we recommend a focus on nursing and therapy models; technical education needs for billing and MDS completion; and relationships with hospitals and physicians, tracking systems, compliance, and possible changes in the physical plant.

CMS has posted a “building-by-building” impact analysis which provides the estimated Medicare Part A payment impact of the RCS-1 model currently proposed.  Click here for the building by building impact data.