Providers Concerned About How CMS' SNF Changes Will Affect Them

The FY 2010 skilled nursing facility (SNF) final rule, which the Centers for Medicare & Medicaid Services (CMS) recently released, includes components that will change some facility processes related to therapy services and ultimately affect resource utilization group (RUG) classification.

Effective October 1, 2010, CMS will:

• Eliminate section T of the Minimum Data Set (MDS)


• Introduce an optional start-of-therapy Other Medicare Required Assessment (OMRA)


• Modify the assessment reference date (ARD) requirements for the end-of-therapy OMRA


• Revise the reporting process for short-stay residents

Although the changes aim to increase the accuracy of payments to facilities, many providers are concerned about the financial pressures and increased workload these changes may cause.

Section T of the MDS is used to estimate how much therapy a resident will receive in the first 14 days of a SNF stay, which drives RUG classification. However, the Government Accountability Office found that "one-quarter of the patients classified using the estimated therapy minutes did not receive the amount of therapy they were assessed as needing," according to the final rule. CMS' decision to remove section T of the MDS will help prevent inappropriate RUG classification due to therapy projection and better align reimbursement with the actual services provided.

Some providers are concerned that the elimination of section T could mean that data would not be captured for days when therapy services were actually provided. CMS addresses these concerns by introducing an optional start-of-therapy OMRA with an ARD five to seven days from the start of therapy.

This optional OMRA would reclassify the resident into the appropriate rehab RUG and payment under this RUG would begin on the day therapy started. CMS will also require that facilities complete an end-of-therapy OMRA within one to three days after all therapy is discontinued, instead of the current requirement to complete this assessment within eight to 10 days after all therapy ends. This will prevent facilities from getting paid a higher rehab RUG for days when no rehab was provided.