Healthcare Reforms 2009 - Implications

The Final Rule for SNF PPS came out on July 31st, 2009. After repeated review of the document, my understanding of its impact are as follows For SNFs effective October 2010 RUGs III to RUGs IV MDS 2.0 to mDS 3.0 Decreased in 1.1% net payments to SNF Change in RUG categories from 53 to 66 ( would be interesting to know more on this) Rehabilitation in SNF Impact Most important is the change in the practice of concurrent therapy provision as we understand it now Current practice allows us to provide therapy to 2 Medicare A patients at the same time and bill each patient the whole time. This allowed therapy practitioners to manage their patient schedule and caseload effectively especially given the shortage of skilled clinicians especially in the SNF practice setting Starting October 2010, concurrent therapy delivery will mean that the total time spent with 2 patients simultaneously will be split and billed as such. This would mean that clinicians will not be able to use the current efficiency strategy to effectively attend to the patients they are currently being able to- significant negative impact for both to the SNFs and Rehab industry Let us further observe how else the changes will impact the rehab industry OMRA days of 8-10 days reduced to 1-3 days post therapy discharge- Again little room for any make up of the over delivery of minutes beyond what is allowed for each category- fair enough Start of Care OMRA will allow to start a new assessment if therapy is initiated instead of waiting until the scheduled assessment window starts- this is good news If the patient is discharged prior to reaching their 5 day assessment, they may not receive any higher RUG level than a Rehab High- Not bad T section that is currently allowed for RH and RM patients to be eliminated- This will have a significant negative impact especially for those SNFs that admit patients receiving dialysis etc.. So far, the above bullets are a fair summary of my reading and comprehension of the final rule document More to come....Stay tuned as Medicare B rules are released hopefully sometime soon Happy Reading and email me if have a different read or need further clarification- I am no expert but have familiarized myself to ensure I make sense when training clinicians