The Centers for Medicare & Medicaid Services is proposing to allocate group therapy minutes in the same manner that concurrent therapy minutes are allocated. For example: Four patients receiving group therapy for one hour would be recorded as 15 minutes each. CMS also noted that it believes the most appropriate group therapy size for the SNF setting is four patients.

Prior to MDS 3.0, many therapy departments opted for concurrent treatment vs. group, due to the 25% allowance calculation. After the implementation of MDS 3.0, however, therapy departments have opted more for group treatment vs. concurrent, due to the 50% reduction in concurrent minutes.

Reducing the group allowance would only continue to hinder therapy departments in providing full treatment to the entire caseload. As a therapist, I greatly recognize the clinical and emotional benefits of group therapy.

When conducted properly, groups can significantly improve the clinical outcomes for many patients. It provides variety to the day-to-day routine treatment. Many times it helps motivate and improve socialization amongst patients.

In addition, implementing the proposed group calculation would almost be impossible. According to current regulations, a group treatment may consist of two to four patients. The calculation is unfair when applied with a small (two- or three-patient) group. By simply creating more confusion, CMS has made it more difficult for providers. In turn, providers are still expected to be ready to provide the best treatment approaches and use strong clinical judgment without government influences.

CMS has also stated that based on first-quarter fiscal 2011 data, group utilization was at approximately 9%. This demonstrates that group therapy is not being excessively used due to the drop in concurrent therapy services. Furthermore, we don’t have any reliable statistics to examine group utilization before MDS 3.0. This proposal is counterintuitive to the current rehab RUGs system and would result in another example of the government imposing rules that overtake clinical practice.

Shelly Mesure (say “Measure”), MS, OTR/L is the president and owner of A Mesured Solution Inc., a rehabilitation management consultancy with clients nationwide. A former corporate and program director for major long-term care providers, she is a much sought after speaker and writer on therapy and reimbursement issues.