09.03.18 | admin

CMS discusses timeline for RCS-I Implementation on ODF

The Centers for Medicare and Medicaid Services (CMS) stated there is no timeline for the implementation of the proposed Resident Classification System-I (RCS-I) on their Open Door Forum (ODF) held on March 8th, 2018.


The Advanced Notice of Proposed Rulemaking (ANPRM) released by CMS in May 2017 introduced

RCS-I as a potential replacement to the RUG based prospective payment system. Since the release, there has been much debate and speculation as to when this new payment system would take effect. CMS had not provided any detail regarding the timeline for its implementation until this most recent ODF.

Summary of ODF

On the March 8th, 2018 ODF, CMS discussed the following pertaining to RCS-I:

• The ANPRM did not finalize any policies regarding RCS-I and therefore there is no specific timeline for its implementation

• CMS acknowledged that time will be needed for software development as well as other stakeholder requirements in order to implement RCS-I

• CMS stated they are unsure if they will be publicly responding to all of the comments and feedback provided by stakeholders after the release of the ANPRM

• CMS acknowledged receiving feedback with regards to how RCS-I could be implemented/integrated with the Unified Payment System for Post-Acute Care (U-PAC) and that they are including this in their analysis

 PTS Take

After the release of the ANPRM last May, PTS along with the majority of PAC providers expected an October 2018 implementation of RCS-I. Over the past month or so, we have heard rumors that the implementation of RCS-I would be delayed. Based on the recent CMS ODF, we believe RCS-I will most likely not be implemented this October, and may very well be integrated into the U-PAC implementation, which would not take effect until 2021.

PTS continues to prepare for a potential October 2018 implementation of RCS-I as it remains a possibility until CMS releases the Proposed Rule for FY 2019 in late April. We believe that this change in payment system will occur, if not this year, certainly in the near future. The Proposed Rule expected in April would also outline any changes to the current ANPRM outline of RCS-1.

PTS will continue to monitor for updates and keep our valued partners informed.

If you have any questions, please contact Matt Nash, Vice President of Strategic Development: mnash@preftherapy.com