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Category: Compliance
CMS Releases FY 2023 Proposed Rule
BACKGROUND
The Centers for Medicare and Medicaid Services (CMS) are legally required to update the Medicare payment rates and quality programs on an annual basis. Each April, CMS publishes a proposed rule for the upcoming fiscal year (FY) and opens a comment period for stakeholders to review and provide comments to CMS before releasing the final rule.
WHAT YOU NEED TO KNOW
On April 11th CMS issued proposed rule CMS-1765-P for FY 2023. This proposed rule contains many areas of importance and significance for SNF providers specifically as it relates to payment, quality, staffing, and more.
Preferred Therapy Solutions is thoroughly reviewing the proposed rule and has planned an in-depth webinar for May 17th, which has already received program approval from the National Association of Long Term Care Administrators Board (NAB).
Key elements of the proposed rule include:
- PAYMENT UPDATES
CMS estimates the aggregate impact of payment policies would result in a decrease of approximately $320 million in Medicare Part A payments to SNFs in FY 2023 - The actual payment update for FY 2023 is a 3.9% increase based on SNF market basket and forecast error adjustments but this increase is offset by a 4.6% decrease in SNF PPS rates as a result of a proposed recalibrated parity adjustment
- An additional $186 million in reductions is estimated based on the SNF VBP program
UPDATED BASE RATES FOR PDPM COMPONENTS
PATIENT DRIVEN PAYMENT MODEL
- Recalibrating the PDPM Parity Adjustment
- The purpose of the parity adjustment is to ensure budget neutrality between RUG-IV and PDPM
- In last year’s proposed and final rules, CMS shared that the transition from RUG-IV to PDPM was not budget neutral with a 5% increase in Medicare Part A payments to SNFs under PDPM. They sought feedback from stakeholders regarding how and when to recalibrate the PDPM parity adjustment, but never proposed an actual parity adjustment
- In this year’s proposed rule, CMS improved its methodology to determine the necessary parity adjustment and is proposing a 4.6% decrease in PDPM payments
- CMS is proposing to accomplish the parity adjustment by recalibrating all PDPM CMI’s equally (PT, OT, SLP, Nursing, and NTA)
- CMS is proposing to implement the entire recalibration all at once, without delay or phase-in
- CMS is proposing several changes to the PDPM ICD-10 code mappings and lists
SNF QUALITY REPORTING PROGRAM (QRP)
- CMS is proposing to adopt one new quality measure to become part of the SNF QRP for FY 2025: Influenza Vaccination Coverage among Healthcare Personnel (HCP) measure
- CMS is proposing to revise the compliance dates for specific SNF QRP requirements
- CMS is seeking comments on 3 subjects
- Future measures for SNF QRP
- Overarching principles for measuring equity and healthcare disparities
- Inclusion of CoreQ: Short Stay Discharge Measure in the SNF QRP
SNF VALUE-BASED PURCHASING (VBP) PROGRAM
- CMS is proposing to suppress the SNF 30-day All-Cause Readmission Measure for the FY 2023 SNF VBP due to the COVID-19 PHE
- In order to maintain compliance with the statutory requirements of the SNF VBP program, CMS is proposing to do the same process implemented last year as it relates to the SNF VBP
- CMS will continue to withhold 2% of Medicare Part A FFS payments per statute
- CMS will “award” SNF’s 60% of the withhold, resulting in a 1.2% payback
- The proposal will result in 0.8% decrease in Medicare Part A FFS payments for all SNF’s except those that are subject to the Low Volume Adjustment policy
- In order to maintain compliance with the statutory requirements of the SNF VBP program, CMS is proposing to do the same process implemented last year as it relates to the SNF VBP
- CMS is proposing to add two new measures to the FY 2026 SNF VBP and one new measure to the FY 2027 SNF VBP
- FY 2026: addition of SNF Healthcare-Associated Infections Requiring Hospitalization and Total Nursing Hours per Resident Day measures
- FY 2027: addition of Discharge to Community – Post-Acute Care Measure for SNFs
- CMS is seeking feedback on the following for the SNF VBP
- Implementing a Nursing Home Staff Turnover measure
- Scoring methodology and how it converts to incentive payments
- Incorporating adjustments related to health equity
Finally, Preferred Therapy Solutions will be submitting comments and feedback to CMS to advocate for therapy services, SNF providers, and most importantly, the residents we are privileged to serve. We encourage all providers to do the same!
NAB APPROVED WEBINAR
Join our webinar on May 17th to learn more about the proposed rule and how to advocate for our industry and patients. Details and links to join this webinar will be provided at a later date.
Preferred Therapy Solutions continues to provide vital information that may impact rehabilitation management, reimbursement policies, and clinical programs, supported by compliance and regulatory requirements that are necessary for a thorough understanding of practices and procedures. If you have any questions, please contact Matt Nash, Vice President of Strategy and Business Development: mnash@preftherapy.com
WHAT YOU NEED TO KNOW ABOUT OSHA INSPECTIONS
BACKGROUND
On March 7th, the Occupational Safety and Health Administration (OSHA) announced highly focused inspections directed at hospitals and skilled nursing care facilities that treat or handle COVID-19 patients. The timeframe will be from March 9,- June 9, 2022.
WHAT YOU NEED TO KNOW
OSHA’s goal is to expand its presence to ensure the following:
- Continued mitigation to control the spread of COVID-19 and future variants
- Compliance with infection control policies and standards, including appropriate fit testing and required documentation for the use of N95 masks
- Protect the health and safety of healthcare workers at heightened risk for contracting the virus
- Complete follow-up inspections at sites that were previously issued citations
The Department of Labor’s memorandum on OSHA’s inspections can be found here.
Preferred Therapy Solutions continues to provide vital information that may impact rehabilitation management, reimbursement policies, and clinical programs, supported with compliance and regulatory requirements that are necessary for a thorough understanding of practices and procedures. If you have any questions, please contact Maria Maggi, Vice President of Quality, Outcomes, and Compliance at mmaggi@preftherapy.com
Solutions Syllabus: Quality Measures
Preferred Therapy Solutions is hosting a monthly educational series based on the RAI Manual for coding the MDS to ensure accuracy with Quality Measures (QMs).
Our Solutions Syllabus will provide extensive guidance on the importance of accurate coding of the MDS and the impact on Quality Measures. This educational series will include a comprehensive guide on QM’s and corresponding MDS sections that affect regulatory programs such as 5-Star and are publicly reported through Care Compare. Understanding the data and the significance of coding is vital for SNFs and LTC communities to thrive in the ever-changing healthcare industry.
Throughout the year, we will cover several QMs for an in-depth review. REGISTER NOW FOR THESE INFORMATIVE SESSIONS
MARCH 22 | 1:30 PM | CLICK HERE TO REGISTER
Introduction to QMs: Quality Measures Made Easy
APRIL 26 | 1:30 PM | CLICK HERE TO REGISTER
MDS Section G – QMs Related to Daily Activities and Mobility
This program has been approved for Continuing
Education for 0.50 total participant hours by
NAB/NCERS—Approval #20230425-0.50-A83211-DL
MAY 31 | 1:30 PM | CLICK HERE TO REGISTER
MDS Section J – QMs Related to Falls
NAB/NCERS—Approval #20230530-0.50-A83992-DL
JUNE 28 | 1:30 PM | CLICK HERE TO REGISTER
MDS Section GG QM Self Care & Mobility
This program is pending NAB/NCERS—Approval
INTERDISCIPLINARY PRACTICES DESIGNED FOR OPTIMAL
PATIENT-CENTERED PERFORMANCE
This past January, CMS released their updated Long-Term Care Survey Process Materials. In addition to a focus on infection control policies and procedures, CMS surveyors will now investigate any concerns related to residents who have experienced a significant decline in their condition during the Public Health Emergency. The COVID-19 impact on the elderly population has been significant. There is an increase in isolation, decreased socialization, and limited interaction with caregivers. Understanding the surveyor’s guidance is the first step to a successful survey. Proactive measures, as well as accuracy in baseline data for all residents, will improve the survey process, and enhance the quality of care provided. Click here for the complete article.
COVID-19 PUBLIC HEALTH EMERGENCY EXTENDED
NEWS FROM U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
WHAT YOU NEED TO KNOW
This past week Xavier Becerra, United States Secretary of Health and Human Services, announced the COVID-19 Public Health Emergency (PHE) extension. This extension will be for an additional 90 days. The NEW expiration date for the COVID-19 PHE is scheduled for, Tuesday, July 20, 2021. The United States Department of Health and Human Services official announcement can be located by visiting their website at https://www.phe.gov/emergency/news/healthactions/phe/Pages/COVID-15April2021.aspx
Preferred Therapy Solutions continues to provide vital information that may impact rehabilitation management, reimbursement policies, and clinical programs, supported with compliance and regulatory requirements that are necessary for a thorough understanding of practices and procedures. If you have any questions, please contact Maria Maggi, Vice President of Quality, Outcomes, and Compliance at mmaggi@preftherapy.com.
| LOOK WHAT’S NEW IN TELEMEDICINE CMS Expands Medicare Telehealth Coverage for Speech-Language Pathology and Audiology Services |
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BACKGROUND
Since March of 2020, the Centers for Medicare and Medicaid Services (CMS) has been expanding the list of telehealth services allowed during the Public Health Emergency (PHE). On Tuesday, March 31st, CMS added additional telehealth services including 24 speech and language pathology/audiology CPT codes. The current PHE declaration is currently scheduled to end on April 21st; however, CMS has noted its intent to extend the PHE through the end of 2021.
WHAT YOU NEED TO KNOW
The following are the additional CPT codes now included on the temporarily authorized Medicare telehealth services list for use during the COVID-19 pandemic:
Speech-Language Pathology Services
· 92526, Treatment of swallowing dysfunction and/or oral function for feeding
· 92607, Evaluation for prescription for speech-generating augmentative device
· 92608, Evaluation for prescription for speech-generating augmentative device
· 92609, Therapeutic services for the use of speech-generating device
· 92610, Evaluation of oral and pharyngeal swallowing function
· 96105, Assessment of aphasia
· 96125, Standardized cognitive performance testing
· 97129, Therapeutic interventions that focus on cognitive function
· 97130, Therapeutic interventions that focus on cognitive function (each additional 15 minutes)
To view CMS’s updated list of temporary telehealth CPT codes for 2021, please click here.
Preferred Therapy Solutions continues to provide vital information that may impact rehabilitation management, reimbursement policies, and clinical programs, supported with compliance and regulatory requirements that are necessary for a thorough understanding of practices and procedures. If you have any questions, please contact Maria Maggi, Vice President of Quality, Outcomes, and Compliance at mmaggi@preftherapy.com.
CMS TO HOLD CLAIMS BEGINNING APRIL 1, 2021
BREAKING NEWS FROM THE CENTERS FOR MEDICARE AND MEDICAID SERVICES
WHAT YOU NEED TO KNOW
Per CMS – In anticipation of possible Congressional action to extend the 2% sequester reduction suspension, CMS has instructed the Medicare Administrative Contractors (MACs) to hold all claims with dates of service on or after April 1, 2021, for a short period of time.
- This will not affect providers’ cash flow
- It will minimize the volume of claims the MACs must reprocess if Congress extends the suspension
- The MACs will automatically reprocess any claims paid with the reduction applied if necessary
Click HERE to read the announcement in its entirety on the CMS website.
Preferred Therapy Solutions continues to provide vital information that may impact rehabilitation management, reimbursement policies, and clinical programs, supported with compliance and regulatory requirements that are necessary for a thorough understanding of practices and procedures. If you have any questions, please contact Maria Maggi, Vice President of Quality, Outcomes, and Compliance at mmaggi@preftherapy.com.
KEPRO AND LIVANTA IMPORTANT REMINDER
BACKGROUND
The Quality Improvement Organization (QIO) goal is to complete appeals and quality of care reviews with healthcare providers as quickly and efficiently as possible.
As of October 2020, the Centers for Medicare & Medicaid Services (CMS) requires providers to send medical records for appeals and quality of care reviews to Kepro and Livanta electronically.
WHAT YOU NEED TO KNOW
This new procedure will allow the review process to be time-efficient and will help avoid any potential errors.
- If you are unable to comply with the electronic submission, you must request a waiver from your QIO
- Use your QIO’s online tool to send records
- Refer to the medical request you received for detailed instructions
- Record requests and submission instructions are emailed to your dedicated contact person
- Be sure to update and verify this contact information via your QIO’s online form
Preferred Therapy Solutions continues to provide its partners with vital information that may impact rehabilitation management, reimbursement policies, and clinical programs, supported with compliance and regulatory requirements that are necessary for a thorough understanding of practices and procedures. If you have any questions, please contact Barbara Blatt, Appeal Management Coordinator at bblatt@preftherapy.com.
NEW INTERNATIONAL DYSPHAGIA DIET STANDARDIZATION (IDDSI)
What’s your plan for rolling out the new IDDSI initiative? Preferred Therapy Solutions provides the necessary platforms in developing a crosswalk between IDDSI and Skilled Nursing Facility diets.
The Academy of Nutrition and Dietetics has announced that as of October 2021 IDDSI will be the ONLY texture-modified diet recognized by NCM (Nutrition Care Manual). The National Dysphagia Diet (NDD) and all available resources will no longer be included in the NCM. While participation is not “mandatory” at this time, dieticians and foodservice professionals may be impacted. Many hospital systems have transitioned to IDDSI or are in the process of doing so. Patient safety and a seamless transition of care will make education on the IDDSI diet levels paramount.
The primary goal of the IDDSI committee is to standardize terminology and definitions of food and liquids for individuals with dysphagia across all ages and care settings. The IDDSI framework includes food and drink descriptors along with instructions for easy, reliable, and accessible methods to test different foods and drinks. Contact Matt Nash mnash@preftherapy.com, to learn about Preferred Therapy Solutions clinical programs that are aligned with the new IDDSI standardization.
IDDSI FRAMEWORK
SOURCE: © The International Dysphagia Diet Standardisation Initiative 2019 @ https://iddsi.org/framework. Licensed under the CreativeCommons Attribution Sharealike 4.0 License https://creativecommons.org/licenses/by-sa/4.0/legalcode. Derivative works extending beyond language translation are NOT PERMITTED.
