After a long build-up, the implementation time for the Patient-Driven Payment Model (PDPM) has arrived! In the past few weeks, providers have been making their last-minute preparations for this major payment overhaul. At the same time, the Centers for Medicare and Medicaid Services (CMS) has been clarifying policy, most recently in an Open Door Forum and through finalizing the Long-Term Care Facility Resident Assessment Instrument (RAI) User’s Manual (Version 1.17.1).
The RAI manual updates are mostly clarifications of existing policy, but there are some changes due to the recently enacted final rule for FY 2020. For instance, the manual incorporates changes with respect to the definition of group therapy for Medicare Part A patients, which is now defined as “the treatment of 2 to 6 residents, regardless of payer source, who are performing the same or similar activities, and are supervised by a therapist or an assistant who is not supervising any other individuals.”
Here are some of the important clarifications in the RAI Manual:
One PDPM topic that has proven challenging for many providers is the Interim Payment Assessment (IPA). These are truly optional assessments, except for right now as we transition to PDPM!
For all Medicare Part A patients (and possibly some or all Medicare Advantage patients) that are in the SNF on October 1, 2019, an IPA must be completed. For those patients, it is important for providers to open cases early and to document all pertinent information by the Assessment Reference Date (ARD)—to be set no later than October 7, 2019.
Four points to keep in mind as you are making this transition:
After the transition is over (meaning for all patients admitted on or after October 1, 2019), the IPA is truly optional. Consider completing an IPA when the patient’s condition changes and the care delivered will increase the payment. This decision should be an interdisciplinary decision after each component is evaluated. Our HDG Learn webinars have provided scenarios describing when IPA completion makes sense.
Although this is considered a “hard transition” from RUGs to PDPM, it does not mean that it needs to be hard for providers. HDG can help with education and training, evaluation of operational readiness, post-implementation follow-up (including auditing), clinical programming, and strategic positioning. Please contact us at 763.537.5700 or firstname.lastname@example.org and visit our website.
Authored by: Brian Ellsworth, MA,
Vice President, Public Policy and Payment Transformation
RN, MDS and Reimbursement Consultant