Reviewing RUG levels
From the Medicare Benefit Policy Manual Chapter 8, we know rehabilitation skilled level of care requires the delivery of skilled therapy five distinct days a week. While this requirement is usually easy to meet with more than one therapy discipline treating the resident, the MDS does not currently capture how many calendar days therapy was provided in the seven-day look-back period.
Note that the Rehab Medium category requires only five total days of any combination of the three therapy disciplines. Without an audit of the therapy documentation, it can't be determined if you are meeting the “five calendar days” requirement.
The Centers for Medicare & Medicaid Services is addressing this issue in the 2014 prospective payment system rule by adding MDS item O0420: “Distinct Calendar Days of Therapy.” This will capture the number of unique days therapy was provided.
The new MDS item itself is straightforward, but what will this mean for your Rehab RUG volume?
In order to assess this change, PointRight studied 1.3 million PPS rehab assessments from calendar year 2012. In this sample, 10% of all rehab RUG assessments were assigned to the Rehab Medium category. Of the Rehab Medium assessments, 56.8% did not have one discipline providing the five days of treatment.
Prior to billing, consider an ongoing audit of records containing a Rehab Medium RUG as part of your compliance plan. For those residents who are at the Medium level, check the therapy grid. If the distinct days the resident received services were four or less, the care delivered fails to meet the requirement for rehab skilled level of care. You should also pay attention to those long weekends and therapy absences that may miss the five-day requirement and result in missed rehabilitation RUG assignments.
You should pay close attention to the management of treatment days and scheduling of resources. October is close, and the time to review your facility's processes and compliance efforts is now. n