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.