Medicare Part A SNF Payment System Reform: Introduction to Resident Classification System - I ZIMMET HEALTHCARE 2018

Similar documents
Medicare Part A SNF Payment System Reform: Introduction to Resident Classification System - I

Objectives 9/18/2018. Patient Driven Payment Model(PDPM) Janine Finck Boyle, MBA/HCA, LNHA Vice President of Regulatory Affairs Fall 2018

2/20/2018. Resident Classification System RCS-1. CMS Proposal

SNF proposed rule revisions to case-mix methodology

6/12/2017. The Rumor is True: A New PPS Payment System is on the Horizon Presented by: RKL, LLP Senior Living Services Consulting Group

CMS Proposed SNF Payment System -- Resident Classification System: Version I (RCS-1)

The Shift is ON! Goodbye PPS, Hello RCS

Goodbye PPS: Hello RCS!

Proposed RCS-1 & It s Impact on Therapy Services- Will it Happen? Krista Olson, MS,CCC-SLP

Patient Driven Payment Model (PDPM) and the MDS: A Total Evolution of the SNF Payment Model

What Every Administrator Needs to Know About the PROPOSED Patient Driven Payment Model (PDPM)

Patient-Driven Payment Model

CMS Requirements of Participation Facility Assessment

Patient Driven Payment Model 101

The President s and Other Bipartisan Proposals to Reform Medicare: Post-Acute Care (PAC) Reform. Summary

MEDICARE FFY 2017 PPS PROPOSED RULES OVERVIEW OHA Finance/PFS Webinar Series. May 10, 2016

& Reward. Opportunity, Risk. HealthPRO Heritage National healthcare solutions firm specializing in Care ReDesign for top of market clients 9/5/2018

Medicare Skilled Nursing Facility Prospective Payment System

RCS-1. (Resident Classification System-Version 1) New Medicare payment system: What to Expect!

August 25, Dear Ms. Verma:

June 26, Dear Ms. Verma:

Get A Seat at the Table

Health Reform and IRFs

Pitch Perfect: Selling Your Services to LTC Facilities

The Pain or the Gain?

Value Based Purchasing 101. About Matt. Learning Objectives. Harmony Healthcare International (HHI)

January 10, Glenn M. Hackbarth, J.D Hunnell Road Bend, OR Dear Mr. Hackbarth:

CMS (Medicare), Patient Driven Payment Model PDPM. Presented by: Cindy Gensamer, MBA, HSE, LNHA Vice President Absolute Rehabilitation

Equalizing Medicare Payments for Select Patients in IRFs and SNFs

MEASURING POST ACUTE CARE OUTCOMES IN SNFS. David Gifford MD MPH American Health Care Association Atlantic City, NJ Mar 17 th, 2015

Development of Updated Models of Non-Therapy Ancillary Costs

Executive Summary. This Project

Medicare, Managed Care & Emerging Trends

All Medicare Advantage Organizations (MAOs), PACE Organizations, Cost Plans, and certain Demonstrations

Final Rule Summary. Medicare Skilled Nursing Facility Prospective Payment System Fiscal Year 2017

Final Rule Summary. Medicare Skilled Nursing Facility Prospective Payment System Fiscal Year 2016

National Association for the Support of Long Term Care

Medicare Spending and Rehospitalization for Chronically Ill Medicare Beneficiaries: Home Health Use Compared to Other Post-Acute Care Settings

HHGM is Alive and Kicking: How Can You Prepare for What s Next?

Proposed fy17 LTCH PPS: New rules for Quality & Referrals

Post-Acute Care. December 6, 2017 Webinar Louise Bryde and Doug Johnson

Medicare Inpatient Psychiatric Facility Prospective Payment System

Bundled Payment Primer

Medicare Program; Prospective Payment System and Consolidated Billing for Skilled. AGENCY: Centers for Medicare & Medicaid Services (CMS), HHS.

AGENDA. QUANTIFYING THE THREATS & OPPORTUNITIES UNDER HEALTHCARE REFORM NAHC Annual Meeting Phoenix AZ October 21, /21/2014

paymentbasics The IPPS payment rates are intended to cover the costs that reasonably efficient providers would incur in furnishing highquality

Medicare Home Health Prospective Payment System Calendar Year 2015

Comparison of Bundled Payment Models. Model 1 Model 2 Model 3 Model 4. hospitals, physicians, and post-acute care where

Clinical. Financial. Integrated.

All Medicare Advantage Organizations (MAOs), PACE Organizations, Cost Plans, and certain Demonstrations

CPAs & ADVISORS. experience support // ADVANCED PAYMENT MODELS: CJR

FY2018 Proposed Rule: Payment and Quality Reporting

Medi-Pak Advantage: Reimbursement Methodology

Data-Driven Strategy for New Payment Models. Objectives. Common Acronyms

Long Term Care Hospital Clinical Coverage Policy No: 2A-2 Services (LTCH) Amended Date: October 1, Table of Contents

An Initial Review of the CY Medicare Home Health Rule. CY2018 Proposed Medicare Home Health Rate Rule and Much More

HOT ISSUES FACING HOME HEALTH & HOSPICE AGENCIES. Luke James Chief Strategy Officer Encompass Home Health & Hospice

Framework for Post-Acute Care: Current and Future Issues for Providers

Regulatory Compliance Risks. September 2009

A Critique of MedPAC s Post-Acute Care Prospective Payment System Prototype

Frequently Asked Questions (FAQ) The Harvard Pilgrim Independence Plan SM

MEDICARE UPDATES: VBP, SNF QRP, BUNDLING

2017 Quality Reporting: Claims and Administrative Data-Based Quality Measures For Medicare Shared Savings Program and Next Generation ACO Model ACOs

THE IMPACT OF MS-DRGs ON THE ACUTE HEALTHCARE PROVIDER. Dynamics and reform of the Diagnostic Related Grouping (DRG) System

The Home Health Groupings Model (HHGM)

Winning at Care Coordination Using Data-Driven Partnerships

Value Based Care in LTC: The Quality Connection- Phase 2

Skilled nursing facility services

Medicare 101. Lisa Satterfield, ASHA director, health care regulatory advocacy Neela Swanson, ASHA director, health care coding policy

Compliance Issues under Medicare Prospective Payment for Nursing Facilities. Presented by: Patricia J. Boyer NHA, RN BDO / Heritage Healthcare Group

2/14/2018. Emerging Issues in Medicare: Payment Updates and Hot Topics. Learning Objectives

Using Structured Post Acute Assessment Data as the Raw Material for Predictive Modeling. Speaker: Thomas Martin November 2014

District of Columbia Medicaid Specialty Hospital Payment Method Frequently Asked Questions

Understanding the PEPPER

CMS s RAI Version 3.0 Manual October 2016

Chapter 6 Section 3. Hospital Reimbursement - TRICARE DRG-Based Payment System (Basis Of Payment)

Quality Outcomes and Data Collection

Physician Performance Analytics: A Key to Cost Savings

June 22, Submitted electronically

Seema Verma Centers for Medicare & Medicaid Services Department of Health and Human Services Attn: CMS-1696-P P.O. Box 8016 Baltimore, MD

POST-ACUTE CARE Savings for Medicare Advantage Plans

Proposed Rule Summary. Medicare Inpatient Psychiatric Facility Prospective Payment System: Federal Fiscal Year 2015

Payment Rule Summary. Medicare Inpatient Psychiatric Facility Prospective Payment System: Update Notice for Federal Fiscal Year 2013

How to Win Under Bundled Payments

CY 2018 Home Health PPS Proposed Rule

Clinical Documentation Improvement (CDI) Programs: What Role Should Compliance Play?

Leveraging Your Facility s 5 Star Analysis to Improve Quality

You re In or You re Out: Determining Winners and Losers Under a Global Payment System

Paying for Outcomes not Performance

CJR Final Rule: Policy Changes and Strategies for Bundled Payment Success

CY2019 Proposed Medicare Home Health Rate Rule and Much More

State FY2013 Hospital Pay-for-Performance (P4P) Guide

September 22, 2017 VIA ELECTRONIC SUBMISSION

Acting Assistant Secretary for Planning and Evaluation Centers for Medicare & Medicaid Services Department of Health and Human Services

COMMONWEALTH OF KENTUCKY OFFICE OF INSPECTOR GENERAL AND MYERS AND STAUFFER LC PRESENT MDS CODING AND INTERPRETATION ANSWER SLIDES

The Future of Post-Acute Care Under Value-Based Payment

New Quality Measures Will Soon Impact Nursing Home Compare and the 5-Star Rating System: What providers need to know

Observation Coding and Billing Compliance Montana Hospital Association

2015 Executive Overview

Transcription:

Medicare Part A SNF Payment System Reform: Introduction to Resident Classification System - I

Introduction to the Resident Classification System - I Concepts Structure Implications

RCS is NOT the Unified Post-Acute Payment System IMPACT Act mandated MedPAC to outline a unified payment system that would replace the four current post-acute care Medicare payment systems (SNF, HHA, IRF, LTCH) Objective is to base payment on patient characteristics rather than setting or amount of therapy furnished (significant redistribution of PAC dollars) IMPACT Timeline: Propose system by 2023, then implement MedPAC demonstrated that the system is highly feasible & accurate; recommends implementation in 2021 with 3-year optional phase-in See June 2017 MedPAC Report to Congress, chapter 1 for details

About RCS-I Advanced Notice of Proposed Rulemaking (5/4/17; CMS-1686) Public comment period extended from 6/26 to 8/25/17 and left open ended Based on extensive research and TEPs (possible refinements) Target date is October 1, 2018 Likelihood of implementation? Budget Neutrality assumed (Parity adjustments) No mention of phase-in / blend-in but possibility Improvement over RUGs? Shift from Volume to Patient Characteristics as $ driver

About RCS-I NO CHANGE IN MEDICARE CLINICAL / TECHNICAL ELIGIBILITY REQUIREMENTS Focus on reducing administrative burden for providers MDS remains basis for rate setting, but 5-day sets the Composite score for the entire benefit period (assuming no discharges or sig. changes) Remaining PPS MDS schedule is eliminated, including COTOs Sets up benchmarking mechanism from admission discharge Recognizes disproportionate costs during first days of stay Frequency / Amount of therapy does not impact reimbursement Therapy is just another component of the care plan Nursing acuities, Diagnosis coding & certain Ancillaries drive revenue

RCS Structure RUG-IV contains 3 rate components: Therapy, Nursing (including NTAs) and Overhead Blended into one of 66 distinct per diem rates RCS includes 5 distinct, (4 variable) rate components: PT/OT (30 categories) SLP (18 categories) Nursing (43 RUGs) Non-Therapy Ancillaries (6 levels) Overhead / Non-Case Mix Adjusted (1 rate) How many possible combinations??? N T O Per Diem RUG 1 of 30 1 1 of 18 Composite 1 of 43 1 of 6

Possible RCS Rate Combinations PT/OT: 30 SLP: 18 Nursing: 43 NTA: 6 Overhead: 1 While there are technically 139,320 possible composite combinations, many are mutually exclusive 139,320

PT/OT SLP Nrsng NTA OH 30 categories 18 categories 43 RUGs 6 groups 1 CBSA RCS Composite RCS: Where Do We Start? One step at a time Each component has its own grouping process using different variables and scoring methodologies

Why is the Patient Here? 10 Clinical Categories capture the range of general resident types found in SNFs MDS Section I: ICD-10 code Primary reason for SNF stay DRG Mapping Major Joint Rep. or Spinal Surgery Non- Orthopedic Surgery Acute Neurologic Non-Surgical Orthopedic/ Musculoskeletal Orthopedic Surgery (Except Major Joint) Cancer Acute Infections Pulmonary Cardiovascular & Coagulations Medical Management

The 10 categories are collapsed into 5 for PT/OT Major Joint Rep. or Spinal Surgery Non- Orthopedic Surgery Acute Neurologic Other Orthopedic Medical Management Major Joint Rep. or Spinal Surgery Non- Orthopedic Surgery Acute Neurologic Non-Surgical Orthopedic/ Musculoskeletal Cancer Orthopedic Surgery (Except Major Joint) Acute Infections 2 for SLP Acute Neurologic Non- Neurologic Medical Management Pulmonary Cardiovascular & Coagulations

Physical / Occupational Component Calculation Clinical Category (5) Functional Score (3) Cognitive Impairment (2) Major Joint Rep. or Spinal Surgery Other Orthopedic Non-Orthopedic Surgery Acute Neurologic Medical Management 14 18 8 13 0 7 Intact or Mildly Impaired Moderately or Severely Impaired Clinical: MDS Section I8000 / I0020 Primary reason for SNF stay (ICD-10) Functional: G Trans, Eating, Toileting: Self Perf only Cognitive: C Cognitive Function Scale All patients score in one PT/OT group no matter if they receive therapy (or how much)

PT/OT Functional Score RCS PT/OT scoring differs from RUG-IV ADL system Transfers, Eating and Toileting Self-Performance scores only Each ADL scored on a 0 6 scale; (v. 4 in RUG-IV) 0 18 point range Unlike RUGs, higher point totals represent lower dependence; Fully functional residents are reimbursed at the highest rates Greater need reduces PT/OT rate but increases RCS Nursing RUG The difference in net impact varies for each component score Nursing increase may or may not exceed PT/OT increase Any inflexible capture strategy may be counter-productive

RCS: PT/OT Functional Score v. RUG-IV: Self-Performance Scale RCS-I Scoring

PT/OT Case-Mix Classification Groups See handout for complete listing of case-mix groups

Speech Language Pathology Component Calculation Clinical Category (2) Swallowing Disorder or Mechanically- Altered Diet (3) SLP Related Comorbidity or Mod. to Severe Cog Imp (3) Acute Neurologic Non- Neurologic Both Either Neither Both Either Neither MDS Section Clinical: I8000 Sw Dis: K0100Z MA Diet: K0510C2 Comorb: Misc. Cognitive: C (CFS) All patients score in one SLP group no matter if they receive therapy (or how much)

SLP Related Comorbidities

SLP Case-Mix Classification Groups See handout for complete listing of case-mix groups

PT/OT & SLP: Cognitive Function New cognitive measure: Cognitive Function Scale (CFS) Combines Brief Interview for Mental Status (BIMS) and Cognitive Performance Score (CPS) into one scale Note: Impairment reduces PT/OT but increases SLP component. PT/OT rate reduction exceeds SLP enhancement (almost always).

43 nursing RUGs Nursing Case-Mix Classification RUG-IV Reimbursement drivers, ADL scoring & splits and hierarchy remain intact Minus Rehab RUGs Reweighted indices 19% HIV/AIDS rate enhancement only applies to this component Triggered by ICD-10 code B20 on the UB-04 See handout for complete listing of case-mix groups and comparison of RUG-IV to RCS CMI weights

NTA Group Classification Non-Therapy Ancillaries Based on the number of services and conditions Hospital look-back as allowed in RUG-IV Greatest rate impact for days 1-3 See handout for complete listing of NTA service / condition drivers and related Points

RCS Rate Composite Calculation 5-day MDS (ARD 1 8) establishes Composite for the entire benefit period with limited exceptions Significant Change / Readmissions Each component has a Base Rate adjusted by CBSA Multiply each Base Rate by respective CMI weight Variable Per Diem Adjustment Factors PT/OT and NTA components decrease as the benefit period progresses (see handout for detail on Base Rates & VPDA)

Significant Change Assessments / Readmissions SCSA would change the resident s RCS-I classification but NOT reset Variable per diem adjustment schedule Interrupted Stay Policy: Resident discharged from SNF and returns to same SNF within 3 calendar days: Stay is treated as a continuation for purposes of RCS classification and VPDA Resident readmitted to the same SNF more than 3 calendar days after discharge, or in any case where resident is readmitted to a different SNF: Resident receives a new 5-day; RCS and VPDA are reset to Day 1 PPS Discharge Assessment required (CMS to add items to track therapy minutes over the course of a resident s stay)

Possible RCS Audit Scope Technical & Clinical Eligibility (7 day/week Nursing, 5/Therapy) No therapy levels to audit cannot be excessive Rationing therapy (too little?) Nursing RUG drivers and end splits Lock & Drop patterns ADL scoring NTA drivers Medical necessity, method of administration, supporting documentation Justification for Significant Change assessments DRG ICD-10 assignment ( Mapping )

DRG Mapping 757 active MS-DRGs in 2017 Medicare Severity Diagnosis Related Group: The system of clinically classifying a Medicare patient s hospital stay into groups in order to set payment Diagnoses drive variable RCS components Link to MDS: ICD-10 Coding Section I: Primary reason for SNF stay Secondary & Tertiary codes DRG ICD-10

RCS Operations Implications Admissions decisions Profitability profiles change Target length of stay Billing and corrections; time limitations? Financial modeling / revenue projections Revenue allocations Impact on managed care contracts / rates / APMs Hospital-based resurgence? Assessment burden MDS staffing & qualifications No margin for error on 5-day We need New Analytics

Therapy Implications No treatment minimums, but ANPRM specifies limits of 25% each for Concurrent and Group of whatever formal therapy is provided No RUG / COTO management Department staffing requirements and ratios (% Assistants, Techs) Development of therapy-centric programs under the direction of licensed staff (Activities, Restorative Nursing) Alternative modalities (Acupuncture, Therapeutic Massage, Chiropractic) Outsource v. In-House management considerations: Pricing therapy component: no direct link to reimbursement may incentivize over/under-utilization depending on contract structure Reconciling Dx to need, inverse ADL / Cognitive revenue issues

RCS Reimbursement Implications Facility-specific revenue transition analysis: Budget neutral redistribution creates Winners & Losers Comparison to RUG-IV transition projections Changes in Provider behavior Parity adjustment / Recalibration risk Relative values among rate components Realizable value of non-therapy payment drivers Reimbursement-sensitivity & documentation requirements Diagnosis mapping & coding Understanding NET revenue impact of ADL & Cognition coding Timing of NTA drivers

Simplified examples using 2017 NYC rates RCS rate simulator available at zhealthcare.com Non-medically complex post-knee replacement Moderate ADL assistance No co-morbidities or NTA services 2 hours of therapy per day, 6 days per week RUG-IV score = RUB $730.96

Simplified examples using 2017 NYC rates RCS rate simulator available at zhealthcare.com Dialysis Moderate ADL assistance Wound, IV meds, Transfusion 65 minutes of therapy per day, 5x per week RUG-IV score = RHB $491.79

Simplified examples using 2017 NYC rates RCS rate simulator available at zhealthcare.com Impact of capturing Respiratory Therapy and Depression

Medicare Data Analysis Market Analysis DRG 194 DRG 247 DRG 870 DRG 373 DRG 292 DRG 190 DRG 470 Hospital Medicare Claims Submitted Facility CBSA 851 852 898 998 1,191 1,214 1,545 37% 35% 33% 31% 29% 27% Medicare Advantage Penetration 34.9% 32.2% 26.1% DRG 872 DRG 291 DRG 871 1,875 1,913 2,150 25% 2015 2016 2017 County State Nation 238,056 FFS BENEFICIARIES Market Saturation and Utilization, by Facility County 10,879 SNF USERS 88 SNF PROVIDERS 123.6 AVG. USERS PER PROVIDER 4.6% USERS OF FFS BENEFICIARIES

Medicare Data Analysis Hospital Referral Sources Hospital Referrals to ABC Care Center 250 $3,500,000 200 201 190 $3,000,000 $2,500,000 150 $2,000,000 100 50 75 62 45 $1,500,000 $1,000,000 $500,000 0 Hospital 1 Hospital 2 Hospital 3 Hospital 4 Hospital 5 $0 Referrals Medicare Payments

Medicare Data Analysis SNF Part A Referrals by Hospital SNF Referrals (#) Referrals (%) ALOS Cost per Admit 5 Star Re-Hosp (%) D/C Community (%) Facility #1 254 17.7% 31.5 $20,349 **** 23.5% 58.2% Facility #2 246 17.2% 33.6 $21,874 *** 18.2% 60.5% Facility #3 201 14.1% 27.1 $17,615 ***** 17.9% 61.4% Facility #4 192 13.4% 28.9 $19,508 ** 22.5% 57.6% Facility #5 150 10.5% 30.2 $19,328 ***** 21.0% 60.1% Facility #6 104 7.3% 34.6 $22,075 *** 20.4% 59.7% Facility #7 88 6.2% 35.7 $23,276 **** 17.7% 57.9% Facility #8 76 5.3% 28.1 $18,518 *** 18.9% 52.2% Facility #9 60 4.2% 30.9 $19,745 * 26.4% 54.5% Facility #10 58 4.1% 36.9 $24,871 *** 23.4% 57.8%

Medicare Data Analysis Referring Hospital Pain Points XYZ Hospital DRG Volume & Re-Hospitalization Rate 1,400 1,200 1,000 800 600 400 200 0 1,156 1,058 998 970 901 865 800 798 DRG 871 DRG 291 DRG 470 DRG 190 DRG 373 DRG 194 DRG 885 DRG 690 35% 30% 25% 20% 15% 10% 5% 0% Medicare Claims Re-Hospitalization

Medicare Data Analysis Episodic Cost Competitive Analysis Facility Episodic Cost Competitor Episodic Cost Respiratory Episodic Cost Comparison Facility Competitor Clinical Category Episodes Episodes Pneumonia Sepsis 75 $14,987 66 $15,874 AMI Major Joint 68 $8,512 101 $9,254 UTI CHF 64 $11,521 74 $13,654 Stroke Stroke 62 $17,085 52 $16,958 CHF UTI 55 $14,954 40 $17,878 Major Joint AMI 49 $10,098 61 $12,568 Sepsis Pneumonia 46 $12,545 42 $12,085 Respiratory 41 $13,654 38 $11,097 $0 $3,000 $6,000 $9,000 $12,000 $15,000 $18,000 Competitor Episodic Cost Facility Episodic Cost