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REVISED Medicare RUGs IV Changes. Aging Services of Minnesota District Meetings January 2010. Keys to Analyzing RUGs IV. Understand the principal changes in RUGs IV Identify which residents move to a new RUG class and which do not Compare RUG IV rates to RUG III rates
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REVISED Medicare RUGs IV Changes Aging Services of Minnesota District Meetings January 2010
Keys to Analyzing RUGs IV • Understand the principal changes in RUGs IV • Identify which residents move to a new RUG class and which do not • Compare RUG IV rates to RUG III rates • Calculate the days for each resident • Change in SNF revenue = • # residents x change in rate x # days • AAHSA calculator estimates Medicare revenue • Take into account MDS 3.0 changes
Overview of RUGs IV Changes • Major shift of $ from therapy to nursing care • System to be budget neutral for Medicare • Higher indices for nursing; lower for therapy • New indices based on STRIVE study • Elimination of three “loopholes”
Overview of Changes (cont.) • New short-stay therapy payment calculation • New domain—Special Care split into two • Shifting of some services to different RUGs • Most domains have changes in qualifiers • 13 new RUGs (total of 66) • Changes in ADL index • [Index maximization continues, so you get the highest rate the resident qualifies for]
New Rates for Selected RUGs RUGs III RUGs IV Extensive Services • SE3 $352.23 ES3 $587.05 • SE1 $270.66 ES1 $411.15 Special Care • SSC $266.21 HE2 $398.58 • SSC $266.21 LE2 $362.28 • SSA $248.42 HB1 $293.87 • SSA $248.42 LB1 $249.20 Clinically Complex • CC2 $264.73 CE2 $323.19 • CA1 $208.37 CA1 $198.94
Therapy Rates Therapy rates will go up, but . . . • RUX 720 Min $646.57 $808.91 • RUL 720 Min $578.35 $789.36 • RHX 325 Min $404.68 $658.51 • RHL 325 Min $395.78 $583.02 • RUC 720 Min $562.03 $603.68 • RUA 720 $499.74 $497.58 • RVC 500 Min $439.87 $517.63 • RVA 500 $385.00 $443.64 • RHC 325 Min $375.02 $451.89 • RHA 325 $337.94 $354.16 • RMC 150 Min $343.20 $398.46 • RMA 150 $328.37 $302.12
Loophole #1: Estimated Therapy • No more estimated therapy (section T) • Only therapy actually provided will count • GAO found that one fourth of residents did not receive the amounts of therapy estimated in section T • Check each resident’s actual therapy minutes against the estimate in section T • If you contract for therapy, you may need to revise your contract.
Loophole #2: Concurrent Therapy • Limit will be 2 residents per therapist • Separate calculations for PT, OT, SLP • For each one, count • All minutes of individual therapy • One-half of minutes of concurrent therapy • All minutes in group therapy, subject to limit of 25% of total therapy minutes • If 25% limit applies, then (#1 + #2)*1.33 for adjusted therapy minutes.
NEW: Short-Stay Therapy ! • Divide total therapy minutes (previous slide) by number of days of therapy = Ave. Therapy Minutes • Must meet six qualifiers • Assessment is a Start of Therapy OMRA assessment • 5-day or readmit/return assessment completed • ARD on or before 8th day of Part A stay • ARD on Start of Therapy OMRA is on last day of Part A • Therapy started during last 4 days of Part A stay, including weekends • At least one therapy continued through last day of Part A stay
Short Stay Therapy Classes • >=144 minutes RUX/L or RUC/B/A • 100 - 143 min. RVX/L or RVC/B/A • 65 - 99 min. RHX/L or RHC/B/A • 30 - 64 min. RMX/L or RMC/B/A • 15 - 29 min. RLX or RLB/A • ADL splits for Rehab + Extensive Services • 11-16 = X 2-10 = L (except RLX, 2-16) • ADL splits for Rehab • 11-16 = C 6-10 = B 0-5 = A • Except RLB/A 11-16 = B 0-10 = A
Loophole #3: Look Backs • Elimination of hospital “look back” periods • Affects five services: • IV Feeding in last 7 days • IV meds, Ventilator/respirator, Tracheostomy, Suctioning in last 14 days • CMS found services often not provided in SNF • CMS also found that services in hospital did not predict resource use in SNF • Affects residents in High Rehab classes with Extensive Services and in Extensive Services
Hospital Look Backs (cont.) • If services provided in SNF, residents remain in RUG domain (unless they have IV meds, IV feeding, or suctioning) • ES3: Trach & ventilator/respirator • ES2: Trach or ventilator/respirator • ES1: Isolation for infectious disease • If services not provided in SNF, residents move to appropriate Rehab class or lower RUG domain/class • CMS says only 10% of residents will remain in Ultra High Rehab w/Ex. Serv.
Hospital Look Backs (cont.) Examples of Possible Reclassifications • RUX 720 Min $646.57 $808.91 • RVX 500 Min $484.37 $724.25 • RHX 325 Min $404.68 $658.51 • RUC 720 Min $562.03 $603.68 • RVC 500 Min $439.87 $517.63 • RHC 325 Min $375.02 $451.89 • RMC 150 Min $343.20 $398.46
Services Shifted to New Classes • IV feeding moves from Extensive Services to Special Care • IV meds move from Extensive Services to Clinically Complex Examples: • SE3 ($331.57) to HD1 w/IV feeding ($312.02) • SE3 ($331.57) to CD3 w/IV meds ($323.19) • SE1 ($270.66) to HC1 w/IV feeding ($296.67) • SE1 ($270.66) to CD1 w/IV meds ($282.71)
New Special Care Classes/Domains • Two domains: • Special Care High • Includes comatose, septicemia, diabetes w/injections, quadriplegia, COPD, fever with pneumonia or vomiting or weight loss or feeding tube, IV feedings, respiratory therapy for 7 days • 8 classes (HE2 - HB1) • Special Care Low • Includes cerebral palsy, multiple sclerosis, Parkinson’s, respiratory failure with oxygen, pressure or veinous ulcers, foot infections, radiation therapy, dialysis • 8 classes (LE2 - LB1) • End splits are ADLs and signs of depression
New Clinically Complex Classes • Currently six classes (CC2 - CA1) • Will be 10 classes (CE2 - CA1) • Some change in clinical qualifiers • Some current qualifiers move to higher domain (e.g., dialysis, septicemia) • Some qualifiers drop out (e.g., internal bleeding) • Will also include residents that qualify for higher domains except for their very low ADL score • Note: Impaired Cognition and Behavior Problems (8 classes) merge into Behavioral Symptoms and Cognitive Performance (4 classes, BB2 - BA1)
CMS Utilization Projections • RUGs III RUGs IV • Rehab + Ext 36.49% 3.82% • Rehab only 51.75% 75.93% • TOTAL 88.23% 79.75% • Extensive 4.26% 1.04% • Special Care 3.03% 10.11% • Clin. Complex 3.22% 5.58% • TOTAL 10.51% 16.73%
Key Steps for 2010 • Learn the RUG IV classes and their definitions • Learn the new MDS 3.0 • Master the new ADL index • Work with your vendors • Staff training, staff training, staff training
Questions: DARRELL SHREVE, vice president of health policy dshreve@agingservicesmn.org JEFF BOSTIC, director of data analysis jbostic@agingservicesmn.org