CMS releases transition information during RUG-IV call

By: August 24th, 2010 Email This Post Print This Post

During today’s RUG-IV National Provider Call, CMS provided listeners with important information regarding the transition from the MDS 2.0 and RUG-III to the MDS 3.0 and RUG-IV. This issue is that to receive payment for covered days in September 2010, you must have a RUG-III group, and to receive payment for covered days in October 2010, you must have a RUG-IV group. However, although RUG-III can be calculated from the MDS 2.0 and MDS 3.0, RUG-IV can only be calculated from the MDS 3.0. This creates a problem for residents in a Medicare Part A stay whose RUG assignment from one SNF PPS assessment covers days in September and October 2010.

“If we followed our existing policies, everyone would have to do an MDS 3.0 assessment for all residents on October 1, but that is not an attractive option,” said Sheila Lambowitz. “So we have come up with other options to combine assessments and minimize the number of assessments you have to do for a successful transition.”

Ellen Berry described the four options in detail and walked listeners through a few examples. The four options and important information related to each are as follows:

  • May opt for default payment under specific circumstances (in addition to current policy). For example, when a resident’s Part A stay ends 10/01/10 –10/04/10:
    • the SNF may opt to not complete applicable PPS assessment
    • the SNF would be required to complete discharge assessment (OBRA rules apply)
    • the expectation is that this will be rare event
  • May opt to complete MDS 2.0 and MDS 3.0 of the same type – MDS 2.0 in September and MDS 3.0 in early October. For example, a SNF can opt to complete a 5-day MDS 2.0 assessment to generate a RUG-III grouper to cover the September days in the applicable payment window and also complete a 5-day MDS 3.0 assessment to generate at RUG-IV grouper to cover the October days in the applicable payment window. Although this option will require SNFs to complete two assessments for one payment period, it ensures that all covered days will have a RUG assignment based on an assessment.
  • May opt to “substitute” an MDS 3.0 for previous type of MDS 3.0. With this option, a SNF would complete an MDS 2.0 and the next required MDS 3.0 assessment type as substitute for same MDS 3.0. For example, you could complete a 5-day MDS 2.0 to generate a RUG-III grouper to cover the September days in the applicable payment window. You would also then complete a 14-day MDS 3.0 assessment to generate a RUG-IV grouper to cover the October days in the applicable payment window and October days for prior assessment window.
    • Considerations: All covered days may not have a RUG. For example, if a resident is discharged after 10/01 and before allowed ARD of MDS 3.0, the discharge date becomes the ARD of early MDS 3.0 assessment.
  • May opt to “substitute” MDS 3.0 for same type of MDS 2.0. With this option, you would not complete a MDS 2.0. Instead, you would complete the required MDS 3.0 for the required MDS 2.0. However, like the previous option, doing this may mean that all covered days may not have a RUG.

Berry stressed that SNFs must decide which option is best for each individual resident. She also discussed how the transition will affect the short-stay, End of Therapy OMRA, and Start of Therapy OMRA policies.

It is important to note that the transition policy does not apply to OBRA required assessments; OBRA assessments must be completed according to the schedule. The transition also doesn’t apply when payment ends 9/30/10 or sooner or when payment starts 10/1/10 or later. The transition does not apply to the following Medicare start dates:

  • 7/03/10 – Day 90, 9/30 is last paid day for 60-day
  • 8/02/10 – Day 60, 9/30 is last paid day for 30-day
  • 9/01/10 – Day 30, 9/30 is last paid day for 14-day
  • 9/17/10 – Day 14, 9/30 is last paid day for 5-day

In addition to the slides, which contained helpful examples, CMS provided listeners with spreadsheets that listed all the options available based on each effected Medicare start date. You can find the slides and the spreadsheets in the Downloads section of CMS’ SNF PPS Spotlight page.

The third call in the RUG-IV National Provider Call series will be next Wednesday, September 1, 1pm-2:30pm. CMS officials said registration information for this call will be sent out late this afternoon or tomorrow morning.

Comments

By Kelley Scott, LBSW on August 25th, 2010 at 2:06 pm

I listened to the web training yesterday and I now have a lot of questions about the transition. I work at a rural hospital, non-critical access, and we have swing beds. Who could I speak to about my questions and get some answers?

By Linda DeMarchi on August 26th, 2010 at 12:56 pm

How do we set the ARD dates on the crossover?

By Kathy Burmeister on August 26th, 2010 at 4:45 pm

Has anyone heard from their Medicare Advantage Companies how they want to handle this transition? Are they even going to be ready for this?

Hi Mackenzie,

thank you for the update. does these only mean that if I have an ARD for a 30 day assessment which is 9/3/2010. I still have to do an MDS 2.0 and a 3.0 on the same ARD date since the coverage will overlap the payment period between RUG III and RUG IV? thank you!

If I have a resident who is admitted on September 27th and I do a MDS with ARD of Oct 1st. Is there not going to be a RUG that could be translated for 4 days in MDS 2.0 and then crossover to MDS3.0 for day 5?

Fritz – What is the Medicare start date for the assessment you are referring to? If I know this, I will be able to provide you with some more information. Also, when using any of these options, you cannot use the same ARD for two assessments. All MDS 2.0 assessments must have an ARD of September 30 or earlier and all MDS 3.0 assessments must have an ARD of October 1 or later.

Helen – If you would only like to do one assessment for the payment window in your situation, you could complete a 5-day MDS 3.0 assessment with an ARD of October 1-5. This assessment would generate a RUG-III score that will cover September 27-30 and a RUG-IV score that will cover October 1-10.

I highly reccomend that everyone take a look at the spreadsheets CMS developed for these transition options. They spell out the possible ARDs for each option based on the Medicare start date and the type of assessment. You can find them in the Downloads section of CMS’ SNF PPS Spotlight page, to which I provided a link in the article above.

By Lisa Sullivan on September 7th, 2010 at 2:29 pm

Hi, how can i see the answers to the above questions on the transition from rugs 3 to rugs 4?
Thank you.

I just wanted to let everyone know that CMS moved the spreadsheets and slide presentation about the transition options. The materials can now be found under the downloads section of the RUG-IV Education and Training page: http://www.cms.gov/SNFPPS/03_RUGIVEdu.asp#TopOfPage

The file is labeled “August 24, 2010 National Provider Call materials”

I know this is off the subject but I was wondering if there was such a thing as MDS Day or something. They have national nurses week, nursing home week, housekeepers and Cenas… Just wondering. Thanks in advance.

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