CMS' Skilled Nursing Facilities' Final Rule Causes Concerns

Another important component of the final rule is the finalization of the Resource Utilization Group, Version Four (RUG-IV) for implementation in FY 2011. In the final rule, CMS addressed many comments they received about RUG-IV and provided responses and explanations. Ultimately, CMS plans to implement RUG-IV as it appeared in the proposed rule, with a few minor modifications, such as:

• Fever with feeding tube will be added to the Special Care High category


• CMS clarified that dehydration has been deleted as a qualifier in any category, including the Special Care and Clinically Complex categories


• Respiratory failure in combination with oxygen therapy while a SNF resident will be added to the Special Care Low category


• Oxygen therapy while a SNF resident will be moved to the Clinically Complex category


• A patient will also qualify in the Special Care Low category if one of the following is present along with two or more skin treatments: two or more venous/arterial ulcers; and one Stage 2 pressure ulcer and one venous/arterial ulcer

"The simultaneous implementation of the MDS 3.0 and RUG-IV will be a major challenge for facilities, but CMS is giving us plenty of time to prepare," Brown says. "To ensure that the transition is as smooth and successful as possible, SNFs should really begin training their staff and adapting their facility processes now."

To view the SNF final rule for FY 2010, visit the Resources page on MDSCentral.