SNF Guide To FY2015 PPS Final Rule & October 1st RAI User's Manual Updates

FY 2015 Final Rule
HARMONY UNIVERSITY
The Provider Unit of
Harmony Healthcare International, Inc. (HHI)
Presented by:
Melissa Fox, OTR/L
Regional Consultant

FY 2015 Final Rule
The Final Rule will be implemented on
October 1, 2014
Medicare payment rates for skilled nursing
facilities (SNFs) with a 2% increase FY 2015
2.5% market basket increase, reduced by the
0.5% point multifactor productivity adjustment
required by law
Change in the market basket index did not exceed
the 0.5 percentage point threshold, therefore
payment rates for FY 2015 do not include a
forecast error adjustment
Copyright © 2014 All Rights Reserved Harmony Healthcare International, Inc. 2

FY 2015 Final Rule
Urban vs. Rural Status
CMS will adopt the most recent Office of Management
and Budget (OMB) statistical area delineations to
identify a facility’s Urban or Rural status
Includes a one year transition with a blended wage
index for all providers for FY 2015
Some nursing homes have gone from Rural to Urban
categories and vice-versa
One-year blended system, in which reimbursements
will be based on a 50/50 split of a SNF’s former and
new designation

FY 2015 Final Rule
COT
COT OMRA Policy
The Final Rule for FY 2015 revises this
existing COT OMRA policy to permit
providers to complete a COT OMRA for a
patient that was previously classified into a
RUG-IV therapy group but is currently in a
non-therapy RUG
FY 2015 Transition Memo to be released

FY 2015 Final Rule
Therapy Payment Options
The Final Rule includes a discussion of the SNF
therapy payment research currently contracted with
Acumen, LLC and the Brookings Institution to identify
potential alternatives to the existing methodology
used to pay for therapy services received under the
SNF PPS
A report outlining the most promising and viable
options that CMS plans to pursue is available at the
CMS website at:
http://www.cms.gov/Medicare/Medicare-Fee-for-Service-
Payment/SNFPPS/therapyresearch.html

FY 2015 Final Rule
CMS highlighted a trend in the Final Rule
indicating that “the number of therapy
minutes provided to SNF residents within
certain therapy RUG categories is, in
fact, clustered around the minimum
thresholds for a given therapy RUG
category.”

FY 2015 Final Rule
“Given the comments highlighting the
lack of medical evidence related to the
appropriate amount of therapy in a given
situation, it is all the more concerning
that practice patterns would appear to be
as homogenized as the data would
suggest.”

FY 2015 Final Rule
CMS also responded to a comment received in
response to the proposed rule “which highlighted
potential explanatory factors for the observed
trends, such as internal pressure within SNFs
that would override clinical judgment, we find
these potential explanatory factors troubling and
entirely inconsistent with the intended use of the
SNF benefit. Specifically, the minimum therapy
minute thresholds for each therapy RUG
category are certainly not intended as ceilings or
targets for therapy provision.”

FY 2015 Final Rule
“Therefore, services which are not specifically
tailored to meet the individualized needs and
goals of the resident, based on the resident’s
condition and the evaluation and judgment of
the resident’s clinicians, may not meet this
aspect of the definition for covered SNF care,
and we believe that internal provider rules
should not seek to circumvent the Medicare
statute, regulations and policies, or the
professional judgment of clinicians.”

FY 2015 Final Rule
“As discussed in Chapter 8, Section 30 of the
Medicare Benefit Policy Manual (Pub. 100-
02), to be covered, the services provided to a
SNF resident must be “reasonable and
necessary for the treatment of a patient’s
illness or injury, that is, are consistent with the
nature and severity of the individual’s illness
or injury, the individual’s particular medical
needs, and accepted standards of medical
practice (emphasis added).”

RAI Manual Updates
The RAI User’s Manual Version 1.12
is scheduled to be posted to CMS’
Nursing Home Quality Initiatives
website:http://www.cms.gov/Medicare/Q
uality-Initiatives-Patient-Assessment-
Instruments/NursingHomeQualityInits/M
DS30RAIManual.html on or about
September 5, 2014

QIO Changes

Livanta, LLC
The geographic Area 1 and Area 5 were
awarded to Livanta, LLC
Area 1: Connecticut, Maine, Massachusetts,
New Hampshire, New Jersey, New York,
Pennsylvania, Puerto Rico, Rhode Island,
Vermont, Virgin Islands
Area 5: Alaska, Arizona, California, Hawaii,
Idaho, Nevada, Oregon, Washington

KePRO
The contract awards for Areas 2, 3 and 4 were
awarded to KePRO
Area 2: District of Columbia, Delaware, Florida,
Georgia, Maryland, North Carolina, South Carolina,
Virginia, West Virginia
Area 3: Alabama, Arkansas, Colorado, Kentucky,
Louisiana, Mississippi, Montana, North Dakota, New
Mexico, Oklahoma, South Dakota, Tennessee, Texas,
Utah, Wyoming
Area 4: Iowa, Illinois, Indiana, Kansas, Michigan,
Minnesota, Missouri, Nebraska, Ohio, Wisconsin

Memorandum of Agreement (MOA)
Read the entire MOA
On page 1, please enter your provider name twice on page
1 where indicated
On page 7, complete all blank lines including signing your
name electronically or manually. If you are agreeing to sign
electronically, just type in your name. If you wish to sign
manually, of course, you will first need to download the
document.
On page 8, designate an individual from your organization
who will serve as the official QIO Liaison
Send a completed and signed copy of the MOA by email to
QIO

Memorandum of Agreement (MOA)
Send MOA within 30 days of your receipt of this
document to avoid having your organization be
out of compliance with Federal Law. An
organization that does not submit a signed copy
of the MOA will be reported to the Centers for
Medicare & Medicaid Services (CMS) as
violating the Conditions of Participation in the
Medicare program.

Key Points
Beginning August 1, 2014
Update all contact references, address
books, and beneficiary forms to reflect
contact information for specific QIO and
Areas
Remind facilities to return their MAO
If appeals are not responded to have
beneficiary call 1-800-MEDICARE

Register online
Register Online
http://info.harmony-healthcare.com/harmony2014
or by phone (978) 887-8919 ext. 13

SNF Guide To FY2015 PPS Final Rule & October 1st RAI User's Manual Updates

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SNF Guide To FY2015 PPS Final Rule & October 1st RAI User's Manual Updates