Impact of the Final Rule to Therapy Providers

By: Mark McDavid, OTR, RAC-CT, Seagrove Consulting In this year’s SNF PPS Final Rule, CMS has provided for a 1.3% adjustment in the market basket which will increase SNF payments by approximately $470 million or about $7 per Medicare patient day. While this will impact your SNF or SNF client, a bigger impact may come from the changes related to therapy. Beginning October 1, therapy will be required to report both unique therapy days as well as the number of co-treatment minutes in section O provided to a patient. CMS’ original intent of the RUG category Rehab Medium was to have therapy occur on five distinct days in the look-back period; however, the grouper software did not use that logic to calculate the RUG category. Therefore, three days of PT and three days of OT (or ST) would be calculated by the grouper as 6 therapy days and make the patient eligible for a Rehab Medium even if this was actually the same three overlapping days. This year’s Final Rule corrects this issue by requiring the reporting of unique therapy days that therapy was provided in the look-back period. From a practical standpoint, this issue may raise some significant questions in your building. Whereas, a patient who missed one day of therapy in a week (due to being out of facility or because they were ill) would have qualified for Rehab Medium, now will not qualify for a rehab category at all; they would end up in a nursing category if nursing was providing a skill. CMS further clarified that in order to qualify for Rehab Low, the patient would be required to receive 3 unique therapy days as well as the minute and Restorative Nursing criteria. Therapy will also be required to start reporting co-treatment minutes. Co-treatment is “When two clinicians, each from a different discipline, treat one resident at the same time (with different treatments), both disciplines may code the treatment session in full” [Page O-22, RAI User’s Manual]. At this point, the number of therapy minutes provided in a co-treatment mode can all be fully counted towards the therapy minutes reported for that individual for that look-back period. As always, the changes published in the Final Rule will be in full effect for Assessment Reference Dates occurring on or after October 1. About the Author: Mark McDavid is an occupational therapy graduate from the University of South Alabama who went on to complete Resident Assessment Coordinator (RAC-CT) certification from the American Association of Nurse Assessment Coordinators (AANAC). He is an experienced leader within the field of allied health services with a proven track-record of dynamically growing therapy and home health operations for both in-house and contract service companies. After joining Rehab Management, Inc. in 2009, where he managed all clinical staff and programs, they recorded their three most successful years in their 28 years of operation. Mark’s knowledge and application of business strategies has earned national recognition within professional organization through conference speaking invitations and an appointment to AANAC’s Expert Advisory Panel. He currently serves as a board member-at-large for the National Association of Rehab Providers & Agencies (NARA) and oversees the SNF Work Group. Mark has an extensive background in regulatory compliance, MDS, MPPR, manual medical review, functional status coding, and documentation. Recently, Mark began his own consulting firm, Seagrove Consulting, in order to work with a wider audience through training and tailored consulting services to propel companies toward greater prosperity and excellent patient outcomes.