Guest Columns

Fiscal Year 2015: Can you handle it?

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Steven Littlehale
Steven Littlehale

It's that time of the year again! Do the shorter days have you thinking of colorful leaves, a harvest moon, ghouls and goblins on All Hallows' Eve? Or were you a SNF provider waiting for the final rule to go into effect on October 1? I think you will agree the changes this fall represent more “treats” than “tricks.”

One treat was the October 1 revision to the Change of Therapy (COT) assessment policy, which allows providers to complete a COT to reclassify a resident into therapy RUG from a non-therapy RUG in limited circumstances.

How limited? Very! The resident has to have been classified into a RUG-IV therapy group on a prior assessment during the resident's current Medicare Part A stay, had an intervening COT put them into a nursing RUG, no discontinuation of therapy services (planned or unplanned) between day 1 of the COT observation period for the COT OMRA that classified the resident into the current non-therapy RUG-IV group, and the ARD of the COT OMRA that will have reclassified the resident into a RUG-IV therapy group.  In this instance, an optional COT may be completed and it is probably not an option you want to overlook as a provider.

This rare scenario is most likely to occur when a resident is receiving rehab, has enough minutes to get into a rehab RUG, but has only 4 distinct days of therapy delivered. In 2013, PointRight received 4.4 million assessments and of those, 4.2% were coded as COTs. Of those COTs, 0.55% had therapy minutes that would qualify them for a rehab RUG but only had four distinct days of therapy. Still, this is a treat, as providers can complete this optional assessment to move the resident into a higher RUG sooner and get paid for the services they are providing.

The other treats? The pesky Medicare Return/Readmission Assessment type (06) is going away; providers will simply use the 5-Day assessment code (01) for all admission types.

Also, items that screen for mental illness/intellectual disability (A1500, A1510, A1550) will only be captured on comprehensive assessments, and lastly, if a resident elects or discontinues their hospice benefit before the ARD of the admission assessment, no Significant Change assessment is required.

With these treats, providers have less to do! Many updates to titles and text were included with a few clarifications, like the payer source does not determine the Unit Certification or the Licensure Designation (A01410).

And then there are some changes that are probably more like minor Halloween tricks.

Dating the flu shot — An item was added to the Discharge assessment item set: the date the influenza vaccination was received (O0250B). This requirement will be tricky to efficiently collect without some EHS automation support.

Discharged from a Certified Bed — If a resident moves to a non-certified bed (Medicare or Medicaid) in your center, you will need to complete a Discharge assessment, coded as “return not anticipated” and code the resident as going to another nursing home or swing bed.

A new item (A1900) is the date the resident was first admitted to your SNF during the current episode of care. The date will remain constant until the resident is discharged, return not anticipated. Until that event happens, the admission date will remain the same, but the Entry Date (A1600) will change.

When all mixed together, the 2015 changes appear to be quite palatable. Now about those new payment models? Now that sounds like a scary Halloween story!

Steven Littlehale is a gerontological clinical nurse specialist, and executive vice president and chief clinical officer at PointRight Inc.

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