Kerry Dunning, MHA, MSH, CPAR, RAC-CT Kerry Dunning LLC March 2018 SNF Medicare Update Kerry Dunning, MHA, MSH, CPAR, RAC-CT Kerry Dunning LLC March 2018

RCS-1 Postponed During the CMS SNF Open Door Forum, it was announced that the intended start of October 1, 2018 for RCS-1 (Resident Classification System) has been postponed. No potential start date was given. RCS-1 was scheduled to replace RUGs IV, the payment system in place since 1999 for PPS SNF and Swing Bed programs. Take heed: the change was being put in place because of the “overuse” of therapy RUGs without good outcomes

Other Warnings The Office of Inspector General (OIG) performed a review of nursing facility records and found that one-third of the records reviewed did not contain evidence of compliance with Federal requirements regarding resident assessments New requirements for assessments to be done within 48 hours of admission (no longer the “skinny "version”) OIG Audits of MDS (PPS) or Documentation (CAH): Incorrect therapy minutes Missing proof of physician exams Missing proof of physician order changes Missing medical necessity documentation Missing proof of need for skilled level of care Missing/untimely signatures and dates

Some Questions: Do you know the average cost per episode for your swing beds? Do you believe your swing bed program is financially viable? How important is your ALOS to cost and reimbursement? What % of admissions are therapy and why? Who reviews the chart to the detail bill? The claim to the chart? WHO KNOWS THE ANSWERS?

SNF Admitting Diagnoses Congestive heart failure Type II Diabetes Mellitus Status-post TKA (total knee arthroplasty) Status-post THA (total hip arthroplasty) Debility Status-post CVA (cerebrovascular accident) Status-post MI (myocardial infarction) Urinary Tract Infection Wound Infection Status-post pneumonia

Avg Ancillary Cost Hx Ancillary Avg Division Ancillary Avg System Ancillary Benchmark