* Editor's note: As of April 6, 2012, the link below to the memo has been made inaccessible. View a Web cache of the memo here.
The Centers for Medicare & Medicaid Services last Friday posted a memo clarifying nine provider questions about the SNF Prospective Payment System’s (PPS) payment and assessment completion policies, coinciding with the April 1, 2012 changes to the Resident Assessment Instrument process.
Clarifications covered how to set the Assessment Reference Date for unscheduled PPS assessments; how to bill for early Change of Therapy assessments; how early, late and missed unscheduled assessments may create a “compounding effect” with other assessment requirements; and others.
The memo also introduced a new policy, also effective April 1, for how providers should handle interviews on unscheduled PPS assessments.
“Effective April 1, 2012, when coding a standalone unscheduled PPS assessment (COT, EOT, SOT), the interview items may be coded using the responses provided by the resident on a previous assessment, if the interview responses from the previous assessment were obtained no more than 14 days prior to the date those responses will be used on a subsequent standalone unscheduled PPS assessment. This does not change other assessment policies with regard to the frequency of resident interviews,” the memo read.
This policy applies only to standalone unscheduled PPS assessments, according to the memo.