The hope: New skilled nursing payment model still a work in progress
James M. Berklan
College kids are often known for being creative. On this count, my friends and I could proudly be pronounced guilty.
When you're in college, after all, you're young and get energy almost daily from the new ideas you're constantly being presented with. There's a boldness to be attained that's often accompanied with a nothing-to-lose attitude.
That takes us back in time to a few bars in the Cleveland area. At first, we weren't even old enough to legally be in them, but that's where the creative factor comes in. You see, when you're about 6-foot-5 or taller, there are certain things that come easier than others. One of them is passing off being older than you are.
This, of course, is worth gold, er, golden lager, to many a college-aged schemer. The three of us would confidently stride into a local house of imbibement, start casual small talk with some of the congenial residents and accidentally let slip that we were the last three guys recently cut from the Cleveland Cavaliers' pre-season camp. At 6-foot-8, 6-foot-7 and 6-foot-5, it was not an implausible scenario if delivered with the right amount of chutzpah. More often than not, we'd soon each have a beer in our hands — courtesy of our newly found, sympathetic friends.
It didn't work every time, but the “What have we got to lose?” attitude paid off often enough to make fond memories to blog about a few decades later.
It is with that hopeful, “Why not try it?” attitude that skilled nursing providers are being led into the days of the new Patient-Driven Payment Model by skillful Washington advocates. (All of them of legal age and otherwise above board, as far as we know, I might add.)
We are in heady times for payment issues in long-term care, as the summer winds down and anxieties arise over what the new payment system will eventually be. Surely, you've noticed you haven't been able to swing a dead cat since late April without hitting someone offering to prognosticate on the future of PDPM.
That's because, of course, when Uncle Sam pulls out his wallet, providers must pay attention with baited breath. By the end of the month, we should better know what direction PDPM will take. In order for information technology vendors, certain contractors and other schedules to be informed, regulators have to push on with the program now.
Hopes are high at the American Health Care Association, and other provider-advocate houses of knowledge. The Centers for Medicare & Medicaid Services, after all, listened to stakeholders' outcry after the agency first floated the ill-fated RCS-1 program.
The question now becomes, will the agency listen again and further fine-tune to providers', and hopefully beneficiaries', best interests? Enter providers, standing upright and tall, with a “What have we got to lose?” attitude.
Association insiders ARE, after all, the ones in the know. As Mike Cheek, the AHCA's senior vice president for reimbursement, pointed out to me, the “commotion” over the issuance of PDPM is a bit overblown for those who have been closely following along.
“We've known it was coming for a long time. They've worked on their payment system for at least six years with various tests,” he pointed out, referring to CMS. "So I don't think many folks are surprised, at least at the association leadership level."
As for the emergence of PDPM, “We had anticipated seeing ‘RCS-Version 2,' which is what we got — relabeled. When in doubt, rebrand, right?” he mused.
So the question becomes how much credence will CMS give AHCA/provider concerns over the coming weeks and months. Remember: To put into play even for an October 2019 start date, certain stipulations need to be in place quickly in the weeks.
AHCA submitted voluminous comments in May and June for regulators to ponder. By one count, Cheek noted, there are five main concerns and hopes on a wish list.
In brief, they are: 1) Getting broader admission (read: reimbursement) categorizations than those in the ICD-10 coding system, 2) a longer window to make modifications to initial MDS assessments, which under the new system could easily stick a provider/beneficiary with too little or too much, 3) readjust interim payment assessment language (payment adequacy and care access issues come into play), 4) creation of a new stakeholder advisory group to oversee ongoing concerns and 5) concerns over unintended consequences to certain beneficiary populations (such as increased rehospitalizations), and providers themselves, of course.
Cheek and colleagues — and by extension long-term care providers everywhere — are hopeful that an interim final rule would be issued Aug. 1, or shortly before, with perhaps another 60-day comment period to help fine-tune rough spots. Their professorial approach to things like this has worked before.
And as we know from educational college days, it doesn't hurt to play with a “What have we got to lose?” attitude.
Follow Editor James M. Berklan @JimBerklan.