Mediware Rehabilitation Blog

Staffing Transparency in Post Acute Care Lines of Service

How will CMS tweak information gathered for Skilled Nursing Facilities (SNF),  should the SNF 2016 Proposed rule be upheld and how might this ruling affect other PAC providers in the continuous struggle to compare/contrast staffing hours based on service types across a continuum?

If you work in a SNF, most likely you read the recent proposed rule and recommended changes for SNF’s in 2016 reporting guidelines. As CMS aligns reporting requirements to meet the IMPACT ACT of 2014, will this type of reporting be the same for LTCH, IRF and SNF? Only time will tell.

Required Comprehensive Care for Joint Replacement Payment Model

CMS reported that in 2013, there were more than 400,000 lower extremity joint replacement procedures paid by Medicare. Costs exceeded $7 billion for hospitalization alone for those procedures. In addition, CMS states that the quality and cost of care for hip and knee replacement surgeries still vary greatly among providers in relation to outcomes and overall costs.

To study this more fully, Congress provided the Secretary of Health and Human Services (HHS) with the authority to expand the scope and duration of a model being tested through rulemaking, including the option of testing on a nationwide basis through the CMS Innovation Center. The CCJR Model is one such model that is in proposed rule status. A pre-selected 75 Metropolitan Statistical Areas and the facilities in those areas are already “signed up.” CMS is looking for comments regarding the proposals on this model before Sept. 8, 2015.

It's Never too Early to Prepare for the 2016 IRF PAI

In early January of this year, CMS held a provider call to discuss the newest sections of the IRF PAI that will be utilized Oct. 1, 2015. In the previous Rule, they provided a draft version of the IRF PAI so that facilities and software vendors would have sufficient time to roll out the changes. Two new sections that were covered in the call were the definitions and discussions around the new Therapy Mode section and how the care is delivered to patients within the first 2 weeks of their stay with 4 new designations of contact time, and the arthritic condition section that facilities may want to count toward conditional compliance to the 60% rule.

Those on the January provider call had lively discussions with CMS requiring deferred final decisions to a clarification document that is now published at the Inpatient Rehabilitation PPS section of their website. Let\'s discuss these two new items and those published clarifications.

Fact or Fiction, H.R. 2126 Could Kill ICD-10 Implementation?

Can you believe there is a bill in Congress right now, ‘To prohibit the Secretary of Health and Human Services from replacing ICD-9 with ICD-10 in implementing the HIPAA code set standards. Yes, despite all the hard work already completed by the healthcare industry, it is believed that scrapping ICD-10 entirely could be the way to go!  Can that really happen?

When it Comes to Medicare Dollars, Compliance Trumps Innovation

Healthcare quality and performance improvement work is not sexy . It is expensive, painfully time consuming and highly detailed with focus upon improving service in meeting the needs of patients. And, it usually occurs long after the patient encounter. Technology exists to acquire the information needed to accomplish quality and performance objectives but healthcare infrastructures and behaviors are not prepared to take advantage. When costs are excessive and money is limited, the investment decisions in improving quality and performance will always favor short term dollars.

Adopting the New Standard of Practice - Visibility & Transparency

Now is the time to pay attention to detail. If you have kept an untidy watch on the comparability of your operations to local or national benchmarks then it's time to pull out the microscope to examine every type of data that streams from your organization daily. Science 101 has returned with a vengeance to the world of health care and the numbers, even though not understood by most laypeople, will lay at consumers' feet to make a decision. Will you be a star or a sinking ship based on those numbers? 

Winning and Losing in Healthcare

Last week, Mediware hosted its annual conference for respiratory and rehabilitation professionals focusing on “Reaching Peak Performance” with Population Based Healthcare. Coincidentally, Frank Cohen posted a piece on the RACmonitor eNews site about the futility of healthcare compliance and its similarity, and differences, to game playing theory by Dr. John Forbes Nash: The Nash Equilibrium: A Study in the Futility of Striving for Healthcare Compliance. While some will argue that our healthcare system and its operation is not a game, there certainly are many winners and losers in the healthcare environment. All participants are challenged with the accountability for transparency of cost and effectiveness of their participation in the game. I immediately saw the analogy with Cohen’s paper.

Managing Population Health Will Require Peak Performance From all of us

Population health is a term that is widely used in healthcare, but not universally understood. The concept of population health was introduced after the turn of the century when David Kindig and Greg Stoddart defined it as “the health outcome of a group of individuals, including the distribution of such outcomes within the group.” Since then, we have come to appreciate the role health care providers must take to impact those outcomes. Accountability to assume responsibility for health outcomes must include the behaviors of the population.

Advanced Beneficiary Notices, Why and When Needed

Financial disclosure, liability and transparency can cause tremendous discussions in healthcare these days. Not just recently but for some time in the Original Medicare program, notification of patient payment liability has always been encouraged through the use of something called the Advanced Beneficiary Notice, or ABN. As it states, in advance of the beneficiary receiving services, a notice is provided to the individual with information for why the provider believes Medicare may not pay for the service.

Often these disclosures are used in the outpatient therapy practice settings. If you have questions about when it’s appropriate to provide an Advanced Beneficiary Notice, then this blog will help you educate staff and keep resource links handy for complete and accurate notifications.

CHIP Reauthorization Act of 2015 Revisited with Milestone Discussions

The Sustainable Growth Rate formula replaced through the Medicare and CHIP Reauthorization Act (MACRA), may not have been thought of much lately since Congress acted in April.  However, this and the therapy caps exceptions process was reinstated April 1, with redefined manual medical review to begin July 1st and therefore the Act is worth reviewing once more. Exactly what happened with MACRA?  If you're paid based on the physician fee schedule, it's time to review!

Defining Resource Utilization in Post-Acute Care

Every year at this time, CMS issues its proposed rules for how providers will operate and get paid under Medicare. Changes are inevitable and this year’s issue continues to drive home the requirement to submit additional information to feed Congress and policy makers the data needed to figure out exactly what they are paying for in post-acute care.

Comment On the IRH/U Proposed Rule- it is Your Prerogative!

Each year, Inpatient Rehabilitation Hospitals/Units (IRH/U) can be presented with a new set of regulatory challenges and presented those with a relatively short time to prepare yourself and staff to meet those requirements. Fortunately, CMS publishes a 'PROPOSED RULE' when they plan to implement change. During that time, facilities and knowledgeable persons are invited to comment on the proposals made in order to help mold a FINAL RULE expectation. If you are the type to wonder how your facility is always caught up in these changes, you may be the type that wants to review the proposed changes and make comments to CMS so your ideas are considered in addition to or instead of a present proposal. IF SO, please join us for the Inpatient Rehabilitation Hospital/Unit Proposed Rule review...

Quality IRH/U Reporting Deadline: May 15, 2015

Non-Participation in quality reporting in an IRF reduces the standard payment by two percent in a future payment year. The deadline for quarter 4 CAUTI data and Influenza vaccination of your healthcare personnel are due THIS WEEK (May 15) ! There is no time to spare; validate your submissions have or will occur before May 15 to the National Health Safety Network on these two items!

This is so disturbing, CMS has created a new MedLearn Matter on the subject, along with the course of events for how the 2% reduction and appeals can occur. 

Alternative Payment Model Coming to A Healthcare Provider Near You

If you haven't heard much about 'Alternative Payment Models' at all, or all until recently, it is a concept that all healthcare workers need to embrace, acknowledge and understand as soon as possible. Bundled Payment and Accountable Care Organizations have been referenced as Alternative Payment Models (APMs); however, this concept is just beginning and CMS, in their quest to guide payment away from fee-for-service toward 'paying providers based on the quality, rather than the quantity of care they give patients', is entering on a whole new horizon. It's time to take a peek and define when, where and how you feel APM fits into your book of business.