The 2019 Fiscal Year is well underway, and 2019 proper will be here in a hot minute. That makes this as good a time as any to preview some of the changes that have recently been or are about to be rolled out by the Centers for Medicare and Medicaid Services (CMS).
The new CMS rules affect Skilled Nursing Facilities (SNFs) and Home Health Providers. We’ve worked with a number of our clients in these categories to discuss the new rules and what they mean for patient care, reimbursement and the ongoing shift to value within these organizations. As such, we’ve seen some of the structural changes providers are expecting to undergo to meet the new requirements, and we have a pretty good understanding of the subtle intricacies hiding between the lines.
We’re going to share what we’ve learned during these conversations and during careful study of the new rules. As always, if you have any questions about what we cover today and how your facility may personally be affected, be sure to reach out and we’d be happy to provide more insight into your particular situation.
SNF Medicare Payments
The big change on the horizon that every SNF needs to pay attention to is the Patient-Driven Payment Model (PDPM) set to come online next October (2019). As CMS notes, this new case-mix model places an emphasis “on the patient’s condition and resulting care needs rather than on the amount of care provided in order to determine Medicare payment.”
The wording inherently speaks to the ongoing shift to value. CMS will continue taking a closer look at the actual specifics of the patient’s case when weighing the payments it provides to each SNF. As such, skilled nursing facilities will be incentivized to look at the totality of each person’s situation to determine whether or not the right care is being provided. On the other hand, SNFs will be penalized if they’re over-prescribing care or pursuing alternate practices that don’t ultimately aid the patient’s wellbeing.
CMS is quick to point out that the PDPM, the latest version of what was previously labeled the Resident Classification System, will reduce paperwork and its attendant administrative overhead. The move reflects an attitude that the sheer volume of services doesn’t mean as much as the results of the patient’s care, thus disincentivizing piecemeal applications of care where every small task required careful documentation and submission for payment. In the past, this outmoded way of thinking ultimately created a deluge of paperwork that proved impossible for many SNFs to keep up with. The CMS’s newest ruling reels that in.
By most accounts, this is good news. The PDPM enables the care team to implement a more holistic approach to care that CMS wants to emphasize while minimizing exposure to unforeseen penalties.
It still means, however, that due diligence is required to properly classify patients using the “clinically relevant factors” CMS will be looking at to guide care. To meet the threshold of reimbursement, policies may need to shift to accommodate the usage of “ICD-10 diagnosis codes and other patient characteristics as the basis for patient classification.”
In order to account for slight differentiation between SNFs and the litany of different policies every facility has in place to care for patients, CMS will also take into consideration Non-Therapy Ancillaries during payment processing. Reimbursement for “items and services not related to the provision of therapy such as drugs and medical supplies” is designed to cushion the financial exposure SNFs take on when providing care for persons whose administrative, care-based, and other needs are more complex than that of the standard patient population.
Readmissions, Readmissions, Readmissions
We don’t have to wait until 2019 to experience one of the biggest changes brought about by CMS.
This past October, CMS began to implement its Value-Based Purchasing Program (VBP) to SNFs. This rule is all about readmissions, bringing the proverbial carrot and stick to the post-acute space.
If you’re a post-acute SNF and you keep your patients out of the hospital for the 30 days following their discharge, the VBP will now be rewarding you with an incentive payment. But if you fail the established readmission measure, meaning that too many of your patients are experiencing relapses that lead them back to the acute space, your reimbursement rates will be reduced.
Eligible SNFs are going to start feeling the impact of this ruling soon if they haven’t already. This particular shift in CMS’s policies has been a long time coming, and many of our own clients around the country are still processing the ramifications.
You can find additional information about the rules affecting post-acute care at Skilled Nursing Facilities on the CMS Fact Sheet here. It’s a lot of ground to cover, and I encourage you to check it out and let us know if you have any questions about something we haven’t focused on.
Home is Where the Health Is
I want to turn now to the home health space, which was the focus of a rule finalization that happened on Halloween. The good news: it’s anything but spooky for home health providers.
Remember the case-mix changes discussed up above in regard to Skilled Nursing Facilities? Home health is seeing a similar change to the title and methods of the case mix, and these changes are expected to have nearly identical repercussions for administrative tasks and payment of home health providers as they did for SNFs. Like the PDPM, the new Patient-Driven Groupings Model (PDGM) places a greater emphasis on the totality of the patient’s unique characteristics, thereby limiting the administrative hurdles that have traditionally bogged down Medicare reporting.
The news that has us really excited is the ruling regarding remote patient monitoring. For the first time ever, home health agencies will be able to report the implementation and deployment costs of monitoring software to Medicare.
That’s huge. Home healthcare providers will be able monitor vitals, openly communicate with patients and bring the care team together around a modern app-based platform that advances wellbeing, and they’ll be reimbursed for the cost of that progressive-thinking method of care deployment.
We expect to see some big things happen in the home health space as a result of this ruling. Cost is something that holds many facilities back from pursuing exciting innovations in the wearable and health-tracking arenas. In essence, CMS has removed at least a portion of this burden by issuing this new rule.
We’ve covered a lot of ground yet barely scratched the surface of what’s been going on under Seema Verma’s CMS. If you’re a SNF or a home health provider, I encourage you to dig deeper into the fact sheets I’ve linked to in this document and, if you have any questions, please contact us.
In particular, I hope home health providers will really take the time to reevaluate their current initiatives in the care tracking space. The new CMS reimbursement rule leaves the door open for a new era of patient care. We have an unprecedented opportunity to track the most important aspects of a patient’s health data while they experience the comfort of living at home while undergoing therapy and rehabilitation.
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