LTC's 'story of the year' awaiting next chapter
James M. Berklan
Everyone has always thought that a planned new clinical groupings model could bring trouble to providers. But nobody really envisioned this.
Providers and other stakeholders must feel like school children sitting in the principal's outer office, anxiously — if not eagerly — awaiting their fate.
The wait is currently indefinite. A Centers for Medicare & Medicaid Services official said as much during a recent Open Door Forum conference call. The timing of what comes next is up in the air.
Heck of a situation for what the industry's top lobbyist called a "huge, huge deal" and "next year's big battle" last November.
Introduced as an advanced notice of public rule making a year ago, the Resident Classification System was floated for a comment period that was repeatedly extended last year. That was not due to a shortage of comments, either. Comments and worried questions flowed freely. Regulators are still trying to digest and incorporate all of them appropriately.
The new system's planned start, originally pegged for Oct. 1, is now very unlikely. It seems to be a fate that wasn't entirely unforeseen. After all, the new system was born as RCS-1 — as in "RCS-the first version." You have to like a certain dose of candor and reality, especially with government rule making. But starting out with a name that implies "we're not going to get it right" from the start seems a bit off-putting.
Yet, I have to hand it to regulators, who appear to be thoughtfully sorting through the issues. If something as potentially game-changing as this is going to be foisted upon providers, you have to be grateful regulators aren't rushing headlong to instigate it and then pick up the pieces later.
This is the same administration, incidentally, that took a previous administration's monstrous new set of Requirements of Participation and wound up giving an extra year (at least) to get used to Phase 2 of them before levying real penalties.
What's surprised me most about RCS-1, perhaps, is the willingness of some providers to accept it, in whatever form it arrives. One of the most talked-about provisions is a move away from having therapists bill for minutes.
"We do need something to keep providers accountable for the therapy provided since they are paid for it," admitted someone currently entrenched in the therapy community.
Soon enough, it will be time to say goodbye to the current Resource Utilization Groups (RUGS) model, which not infrequently incentivizes overuse of therapy, as well as requesting reimbursements that exceed actual costs of care.
Instead, it's going to be a deeper leap into the value-based payment world. Outcomes, not volume, is where the emphasis will be.
RCS-1 is slated to have four new case-mix categories. Each will have its own case-mix group, reportedly creating a total of 300,000 potential payment groups.
That sounds like plenty of reasons to take time to get it right.
Follow Editor James M. Berklan @JimBerklan.