CMS releases FY 2019 proposed rule, includes RCS-1 replacement

CMS has posted a proposed rule for FY 2019. The proposal not only changes payment rates, but also proposes a new case mix grouping called the Patient-Driven Payment Model, or PDPM. This model replaces the RCS-1 that was proposed in May of last year. According to CMS, this new system has 80% fewer groupings and uses some metrics already collected for quality reporting. CMS says the intention is to lessen administrative burden, streamline the process, …

Ask the expert: Therapy billing

Q: We did an M5/d/c/SOT on a resident that was admitted on 3/6 and discharged on 3/7. All therapies were treated on the last day.
Here is some more information:
ADL RUG IV score: 3
PT: 60 min
OT: 60 min
ST: 25 min
Total: 145 min
We submitted and then received fatal error ID 3804: Inconsistent HIPPS code.
If A0310C equals 1 or 3, then the first character of Z0100A calculated by  the QIES ASAP System must equal R. The RUG score …

Ask the expert: ARD dates

Q: I have a scenario that I find a bit confusing:

Admission: 12/13/12
M5: 12/20/12
M14: 12/27/12
M30: 1/9/13
MD ordered home rehab: 1/11/13
EOT DONE 1/13/13
EOT-R: 1/14 then on 1/20/13

When would the COT be? Can these dates be correct?
A: The ARD dates in the scenario are within the allowable timeframes, providing the M5, M14, M30 are all ARD dates. However, without more information regarding therapy RUG scores, it’s impossible to tell whether the Medicare 14 day was combined with the …

Ask the expert: Hospice coding

Q: If someone is on Hospice and a hospice worker gives that person a bath, which they do in our building, we were instructed that we cannot take credit for it on the MDS—so would we code it not assessed? Doesn’t make much sense, being that it is not one of the late loss ADLs that factors into the RUG calculation, can you advise?
A: Current MDS 3.0 coding policy is very different from MDS 2.0 …