1. 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

2. RCS-1 Postponed
During the CMS SNF Open Door Forum, it was announced that the intended start of October 1, 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

3. 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

5. 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?

6. 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

8. Avg Ancillary Cost
Hx Ancillary Avg
Division Ancillary Avg
System Ancillary Benchmark