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SUBJECT: Updates to the Medical Review Instructions Related to Skilled Nursing Facilities (SNF)
I. SUMMARY OF CHANGES: The purpose of this Change Request (CR) is to ensure the medical review instructions in Publication (Pub.) 100-08 align with the regulatory updates issued in final rule CMS-1696-F that created the Patient Driven Payment Model (PDPM), which replaces the prior Resource Utilization Group (RUG) classification system, effective October 1, 2019.
As a screening tool to identify potential weight problems for adults, body mass index (BMI) has always been important to document, but it gained new importance as a reimbursement factor for Medicare Part A residents under the Patient-Driven Payment Model (PDPM). Here’s what nurse assessment coordinators (NACs) need to know about BMI:
Learn the NTA impact for PDPM
“Residents who are morbidly obese may require a higher degree of nursing effort and skilled nursing care. Likewise, residents at the other end of the scale who are at risk for malnutrition also require more skilled nursing care,” says Pam Duchene, PhD, APRN-BC, NEA, FACHE, RAC-MT, DNS-CT, QCP, vice president of education and training for Harmony Healthcare International in Topsfield, MA.
CMS has revised SNF-focused chapters in the following manuals in the online manual system to account for the Patient-Driven Payment Model (PDPM):
The transition from the RUG-IV to the Patient-Driven Payment Model (PDPM), was a hard transition. SNFs followed RUG-IV PPS scheduling and rules through September 30 and then, on October 1, they began PDPM. However, there is still a transition process that must be followed, and nurse assessment coordinators (NACs) need to fully understand all the requirements. NACs also need to double check all payer types and assessment reference dates (ARDs) and ensure that, by the end of October 7, the facility has completed all steps the process requires. Lastly, NACs may want to consider completing a quick triple check or a billing review to ensure all the conditions of Medicare billing have been met before the end of the transition. While the triple check process is typically reserved for reviewing the previous month’s claims, completing an expedited check by October 7, before the end of the transition, can help reduce the risk of payment penalties. Here are three key steps to a successful transition:
In addition to updating the coding instructions for MDS item I0020B (ICD Code/Resident’s Primary Medical Condition), the Centers for Medicare & Medicaid Services (CMS) made several other changes to version 1.17.1 of the Long-Term Care Facility Resident Assessment Instrument 3.0 User’s Manual compared to the draft version 1.17. Most were expected given the updated presentations CMS officials gave at the August 13 – 14 Skilled Nursing Facility Quality Reporting Program (SNF QRP) training event, as well as the finalized requirements in the Fiscal Year (FY) 2020 Skilled Nursing Facility Prospective Payment System (SNF PPS) Final Rule. These included updates to the definition of an interruption window and changes to the group therapy coding instructions. However, there were also some new updates. For example, CMS established a new 10/01/2019 Cross-Over Rule as part of its MDS modification policy.
Last week, the Centers for Medicare & Medicaid Services (CMS) released the long-awaited version 1.17.1 of the Long-Term Care Facility Resident Assessment Instrument 3.0 User’s Manual. One change from the draft version 1.17 manual highlights some ongoing confusion about how to code ICD-10-CM diagnosis codes in MDS items I0020B (ICD Code/Resident’s Primary Medical Condition) and I8000 (Additional Active Diagnoses) to ensure accurate case-mix classification in the Patient-Driven Payment Model (PDPM).
The ICD-10 code entered in I0020B determines a Part A resident’s default primary diagnosis clinical category for the physical therapy (PT), occupational therapy (OT), and speech-language pathology (SLP) payment components under PDPM. In addition, ICD-10 codes entered in I8000 determine whether the resident qualifies for certain comorbidities under the SLP component (identified in Table 14, “SLP-Related Comorbidities,” in the PDPM Calculation Worksheet for SNFs section of chapter 6 in the RAI User’s Manual) or the nontherapy ancillaries (NTA) component (identified in Table 16, “NTA Comorbidity Score Calculation”).