Imagine going to your computer, logging on to the Internet, putting your patient’s name into a search engine and getting immediate access to everything that was done for that patient to treat current and previous medical problems. With one or two more clicks, you would access summary information, comparing your patient to an appropriately matched population of like patients cared for with conditions and problems matching your patient. Then, another click and a quick analysis of the data would predict best-fit care strategies matched to your patient’s requirement and resources.
Mediware Rehabilitation Blog
On Feb. 2, 2015, the President released his 2016 Presidential Budget Reform documents. In looking back over the past four years when first covering this topic in a blog, I attempted to see what might be in store for post-acute care and in particular, Inpatient Rehabilitation Facilities. Perhaps less is MORE but I'm beginning to wonder how the numbers all add up because, in comparison at best, some savings look fictitious as a 'guestimate' of inconsistency. Let's review...
I left blog #3 in this series with this thought, "Applying site-neutral payment lacks real insight into regulatory realities that have placed IRF access and costs where they are today." Why continue to support more SNF PAC beds in the matrix when regulations have forced most IRFs to be at 60-70 percent capacity or less?
Patients deserving IRF level of care have payment possibilities in the PRESENT IRF PPS payment tool. These payments are less than both SNF and IRF experiences published in the June MedPAC report. I urge you to tell this story to your lawmakers!
Have regulatory changes that steered rehabilitation patients of lesser CMG values away from IRF fueled the growth of other post acute care venues? Have the shifts that occurred made good financial sense to CMS? Have acute care practices and lengths of stay changed over the past 20 years necessitating more robust post-acute care readiness? The answer to these questions hold the key to what lawmakers need to consider when it comes to recommending site-neutral payment in IRFs and SNFs, even for limited orthopedic conditions.
Let's review these concepts in Blog 3 of the series on site-neutral payment and why now more than ever a specialized level of rehabilitation care (IRF) should not be considered comparable in services or payment to a SNF level of care. If patients are screened and directed appropriately based on their real medical and functional needs, there would be no need to concoct 'site- neutral' relationships.
Resources federally mandated to admit and care for patients at a rehabilitation ‘burden of care’ facility and payment based on the IRF PAI driven assessment has historically created acuity payments in higher CMGs. This reality is what fueled the experience noted in the June MedPAC study that, ‘on average’, payments to IRFs, when compared to SNFs, can be higher. In this second discussion on site-neutral payment, and why it should not be considered at this time in Congress, let's review the present possibilities of payments and why we should access those first before paying a site-neutral payment that is not always commensurate with the real burden of care for a patient treated in an IRF.Let's also say that when a patient admitted to an IRF has a lower acuity, the payment available and paid will follow that experience too! Yes, even in an IRF.
Site-neutral payment has been garnering a lot of attention lately, with various government agencies discussing equal pay for equal treatment, and then using actual data files within CMS to make arguments for equal pay. Meeting the Three AIMS of CMS to obtain better value for dollars paid in healthcare is important; however, these studies attempt to neutralize real differences that, in hindsight, cannot be made vanilla in the ways they have applied rationale to make comparisons.
To defend medical necessity, IRF resources, outcomes and patient types have moved to higher acuity. Comparing real costs may show that it costs more, on average, to treat patients in an IRF; however, on average, IRFs do not have the same population of patients they ‘signed up for’ when IRF PPS payment began in 2002. Unless consideration is given to what has caused this shift, discussions on site neutral payment needs to be stopped in its tracks (if it is not too late already) and we need to educate lawmakers about how they got IRFs to realize the differences they are seeing when real patient data is compared.
The ICD-10 date to comply is published again. Will it stick this time? Despite a congressional delay last fall, it appears that CMS is planning to stick to an Oct. 1, 2015 deadline.
Modifier alerts occur when CMS attempts to further differentiate the services provided and whether those services are payable as distinct and separately. Way back in 1996, NCCI edits began and have evolved to mutually exclusive and component codes that are generally considered non-payable on the same date of service. This is true unless you append that line on your bill with the 59 MODIFIER that specifically permits the 'unbundled' payment. How often have you used or needed to use the modifier in your practice? Some facilities, by the nature of what they do, will systematically trigger the need more often. Let's discuss because the new 'X' modifiers are causing some 'ruckus'. There is more than a month to plan and educate... now let's discuss if you are one of those practices!