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The Reingruber Report
The Reingruber Report is a compilation of articles with brief technical information
and materials regarding the long term care industry. This report is not
intended to offer specific advice to any one provider and any application of
the matters discussed herein is dependent upon specific facts and circumstances
of individual situation. No final conclusions on the discussed topics should be
drawn without further review and consultation.
Please
use the link below to access the Summary of CMS MDS 3.0 Training March 7-9,
2012
If you have any questions,
please do not hesitate to contact our office.
Thank you.
100
Suite 300-S
(727) 821-9200 – Main
number
(727) 820-0033 – Fax
number
http://www.reingruber.com/downloads/March
2012 CMS Training Summary Final.pdf
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$523 Calendar Year (CY) 2012 Enrollment Application
Fee for Institutional Providers
Wednesday, December 7, 2011
Institutional providers (i.e., all providers except physicians, non-physicians practitioners, physician group practices and non-physician practitioner group practices) must submit an application fee or hardship exception when initially enrolling, revalidating their enrollment; or adding a new Medicare practice location. The CY 2012 fee of $523.00 is required with any Medicare enrollment application submitted on or after Sunday, January 1, 2012 and on or before Monday, December 31, 2012.
For more information about how the fee was calculated, see the Federal Register Notice. See MLN Article SE1130 to learn how to pay the fee for Medicare enrollment actions.
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From: Skilled Nursing Facility
(SNF) [mailto:SNF-L@LIST.NIH.GOV] On Behalf Of CMS CMSProviderResource
Sent: Friday, July 29, 2011 5:12 PM
To: SNF-L@LIST.NIH.GOV
Subject: CMS ANNOUNCES MORE ACCURATE FY 2012 PAYMENTS FOR MEDICARE
SKILLED NURSING FACILITIES
CMS
ANNOUNCES MORE ACCURATE FY 2012 PAYMENTS FOR MEDICARE SKILLED NURSING
FACILITIES
CASE-MIX INDEXES RECALIBRATED TO BETTER ALIGN PAYMENTS WITH COSTS
Also requires a new
assessment to capture changes in therapy services, and allocation of group therapy time to
ensure payment accuracy
The Centers for Medicare & Medicaid Services
(CMS) today announced a final rule reducing Medicare skilled nursing facility
(SNF) Prospective Payment System (PPS) payments in FY 2012 by $3.87 billion, or
11.1 percent lower than payments for FY 2011. The FY 2012 rates correct for an
unintended spike in payment levels and better align Medicare payments with
costs.
“CMS is committed to providing high
quality care to those in skilled nursing facilities and to pay those facilities
properly for that care,” said CMS Administrator Donald M. Berwick, M.D.
“The adjustments to the payment rates for next year reflect that policy.”
CMS is now recalibrating the case-mix indexes (CMIs)
for FY 2012 to restore overall payments to their intended levels on a
prospective basis. The SNF PPS uses a resource classification system known
as Resource Utilization Groups Version 4 (RUG-IV), which assigns a patient to a
RUG group to determine a daily payment rate. Each RUG group consists of CMIs
that reflects a patient’s severity of illness and the services that a patient
requires in the skilled nursing facility (SNF). In transitioning
from the previous classification system to the new RUG-IV, CMS adjusted the
CMIs for FY 2011 based on forecasted utilization under this new classification
system to establish parity in overall payments. SNFs have been paid under
RUG-IV since Oct. 1, 2010.
CMS found that the parity adjustment made in FY
2011, which was intended to ensure that the new RUG-IV system would not change
overall spending levels from the prior year, instead resulted in a significant
increase in Medicare expenditures during FY 2011. This increase in spending was
primarily due to shifts in the utilization of therapy modes under the new
classification system differing significantly from the projections on which the
original parity adjustment was based.
“Additional data analyzed by CMS since publication
of the proposed rule confirmed the extent of the overpayments that have
occurred since implementation of the RUG-IV system,” said Jonathan Blum, deputy
administrator and director of the Center for Medicare. “We are also making
several improvements to our payment system to strengthen its integrity.”
The FY 2012 recalibration of the CMIs will
result in a reduction to skilled nursing facility payments of $4.47 billion or
12.6 percent. However, this reduction would be partially offset by the FY
2012 update to Medicare payments to skilled nursing facilities. The
update — an increase of 1.7 percent or $600 million for FY 2012 — reflects a
2.7 percent increase in the prices of a “market basket” of goods and services
reduced by a 1.0 percent multi-factor productivity (MFP) adjustment mandated by
the Affordable Care Act. The combined MFP-adjusted market basket
increase and the FY 2012 recalibration will yield a net reduction of $3.87
billion, or 11.1 percent.
For FY 2012, the recalibration will reflect the
intent of the new RUG-IV system to pay SNF providers more accurately based on
the service needs of Medicare beneficiaries in their care. The adjustment
was determined using claims and assessment data from the first eight months of
FY 2011. It will ensure that payments more accurately reflect the resources
required to provide care for the range of SNF patients, including those
requiring more medically complex care.
It is important to note that this recalibration
removes an unintended spike in payments that occurred in FY 2011 rather than
decreasing an otherwise appropriate payment amount. Even with the recalibration,
the FY 2012 payment rates will be 3.4 percent higher than the rates established
for FY 2010, the period immediately preceding the unintended spike in payment
levels.
Along with recalibrating and updating the SNF
PPS payment rates for FY 2012, this final rule makes a number of additional
revisions aimed at enhancing SNF PPS accuracy and integrity. The rule
modifies the patient assessment windows and grace days to minimize duplication
and overlap in observation periods between assessments. The final rule
also:
Clarifies circumstances when SNFs must report
breaks of three or more days of therapy.
- Eliminates the
distinction between facilities regularly furnishing therapy services on a
5- or 7-day basis for purposes of setting the date for the End of Therapy
(EOT) Other Medicare Required Assessment (OMRA).
- Streamlines procedures
for documenting situations involving a brief interruption in therapy,
where therapy resumes without any change in the patient’s RUG-IV
classification level.
- Introduces a new Change
of Therapy (COT) OMRA to capture those changes in a patient’s therapy
status that would be sufficient to affect the patient’s RUG-IV
classification and payment, even though they may not increase to the level
of a significant change in clinical status.
- Provides for the
allocation of a therapist’s time for group therapy (defined in the rule as
a single therapist leading four patients in a common activity) to ensure
that Medicare payments better reflect resource utilization and cost for
these services, and specifically that the therapist’s time is being
appropriately counted and reimbursed.
- Discusses the impact of
certain provisions of the Affordable Care Act, and announces that proposed
provisions regarding ownership disclosure requirements set forth in the
Affordable Care Act will be finalized at a later date.
More
information on this SNF PPS final rule and other health care related news can
be found at www.healthcare.gov,
a new web portal made available by the U.S. Department of Health and Human
Services.
For
further information, see www.cms.hhs.gov/center/snf.asp.
A copy of the final rule is available on the Federal Register website
at: http://www.ofr.gov/OFRUpload/OFRData/2011-19544_PI.pdf
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From: 18 existing FFS provider listservs
[ALL_FFS_PROVIDERS@LIST.NIH.GOV] On Behalf Of CMS CMSProviderResource
[CMSProviderResource@CMS.HHS.GOV]
Sent: Wednesday, August 10, 2011 3:48 PM
To: ALL_FFS_PROVIDERS@LIST.NIH.GOV
Subject: Medicare Providers Must Begin to Revalidate Enrollment By March
2013
All providers and suppliers who enrolled in the
Medicare program prior to Friday, March 25, 2011, will be required to
revalidate their enrollment under new risk screening criteria required by the Affordable
Care Act (section 6401a). (Providers/suppliers who enrolled on or
after Friday, March 25, 2011 have already been subject to this screening, and
need not revalidate at this time.)
In the continued effort to reduce fraud, waste, and
abuse, CMS implemented new screening criteria to the Medicare provider/supplier
enrollment process beginning in March 2011. Newly-enrolling and
revalidating providers and suppliers are placed in one of three screening
categories – limited, moderate, or high – each representing the level of risk
to the Medicare program for the particular category of provider/supplier, and
determining the degree of screening to be performed by the Medicare
Administrative Contractor (MAC) processing the enrollment application.
Between
now and March 2013, MACs will be sending notices to individual
providers/suppliers; please begin the revalidation process as soon as you hear
from your MAC. Upon receipt of the revalidation request, providers and
suppliers have 60 days from the date of the letter to submit complete
enrollment forms. Failure to submit the enrollment forms as requested may
result in the deactivation of your Medicare billing privileges. The
easiest and quickest way to revalidate your enrollment information is by using
Internet-based PECOS (Provider Enrollment, Chain, and Ownership System), at https://pecos.CMS.hhs.gov.
Section
6401a of the Affordable Care Act requires institutional providers and
suppliers to pay an application fee when enrolling or revalidating
(“institutional provider” includes any provider or supplier that submits a
paper Medicare enrollment application using the CMS-855A; CMS-855B, not
including physician and non-physician practitioner organizations; CMS-855S; or
associated Internet-based PECOS enrollment applications); these fees may be
paid via www.Pay.gov.
In
order to reduce the burden on the provider, CMS is working to develop
innovative technologies and streamlined enrollment processes – including Internet-based PECOS. Updates will continue to be
shared with the provider community as these efforts progress.
For
more information about provider revalidation, review the Medicare Learning
Network’s Special Edition Article #SE1126, titled “Further Details on
the Revalidation of Provider Enrollment Information.”
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DADS has issued the
following Information Letter(s):
- Information
Letter No. 11-124: Expansion of Money Follows the Person
Options to Include Programs of All-Inclusive Care for the Elderly (PACE)
- Addressed to:
- All Nursing Facility Administrators
- Program of All-Inclusive Care for
the Elderly Providers
- Information
Letter No. 11-109: Process For Refunding DADS When a Provider
is Paid by Private Insurance
- Addressed to:
- Nursing Facility (NF) Providers
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New Texas Medicaid Payment Rates for Hospices Effective October 1, 2011
November 18,
2011
To: Medicaid Hospice Providers
Subject: Information Letter No. 11-144
Payment Rates Effective October 1, 2011
Dear Provider,
The Texas Health and Human Services Commission (HHSC)
approved rate changes for the Medicaid Hospice program Federal Fiscal Year 2012
based on information provided by the Centers for Medicare and Medicaid Services
(CMS). The new rates, which are effective retroactive to October 1, 2011, can
be accessed through the HHSC Rate Analysis website at the following address:
http://www.hhsc.state.tx.us/rad/long-term-svcs/hospice/index.shtml
Once you access this website, scroll down to the
“Payment Rate Information” heading and click on the link entitled “2012 Payment
Rates to Current”. The county where the hospice recipient received services is
the basis for determining the appropriate rate. The new rates are listed by
county. In addition, CMS has indicated the hospice cap amount of $24,527.69,
for the cap year ending October 31, 2011.
Claims Submission
Providers should continue to bill the Texas Medicaid
and Healthcare Partnership (TMHP) using their normal billing process. Providers
are encouraged to bill electronically. Since the electronic payment system has
been updated with the new rates, a retroactive adjustment will occur allowing
the new rate for claims beginning October 1, 2011; therefore, no additional
action is required by individual providers.
Medicaid Hospice forms and instructions, information
letters, and policy clarifications may be accessed at
http://www.dads.state.tx.us/providers/Hospice/index.cfm. If you have questions
regarding billing and payments for hospice services, please call TMHP at
1-800-626-4117 and select option 1.
Sincerely,
[signature on file]
Pam McDonald
Director,
HHSC Rate Analysis for Long-Term Services and Supports
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OIG: Medicare
Hospices that focus on Nursing Facility Residents
Medicare spending on hospice care for nursing facility residents has grown
nearly 70 percent since 2005. Additionally, hundreds of hospices had a high
percentage of their beneficiaries residing in nursing facilities, and most of
these hospices were for-profit. Compared to hospices nationwide, these
high-percentage hospices received more Medicare payments and served
beneficiaries who spent more time in care. High percentage hospices typically
enrolled beneficiaries whose diagnoses required less complex care and who
already lived in nursing facilities before they elected hospice care.
Medicare currently pays hospices the same rate for care provided in nursing facilities as it does for care provided in other settings, such as private homes. Unlike private homes, nursing facilities are staffed with professional caregivers and are often paid by third party payers, such as Medicaid. These facilities are required to provide personal care services, which are similar to hospice aide services that are paid for under the hospice benefit.
Some hospices may be seeking beneficiaries with particular characteristics, including those with conditions associated with longer but less complex care. Such beneficiaries are often found in nursing facilities. By serving these beneficiaries for longer periods, the hospices receive more Medicare payments, which can contribute to larger profits.
We recommend that CMS (1) monitor hospices that depend heavily on nursing facility residents and (2) modify the payment system for hospice care in nursing facilities. CMS concurred with both of our recommendations. It also agreed that the current payment structure may provide incentives for hospices to seek out beneficiaries in nursing facilities, who often receive longer but less complex care.
To view the full report:
http://oig.hhs.gov/oei/reports/oei-02-10-00070.pdf
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