Will RUGs be swept under the rug?

The Centers for Medicare and Medicaid Services (CMS) has released an advance notice of proposed rule-making that could change everything about RUG billing in nursing homes. In particular, CMS is seeking opinions on ways to replace the RUG IV model, including ideas to replace it “with the RCS-I case mix model, used to assign SNF Part A residents to payment groups that reflect varying levels of resource intensity.”

For many SNFs, that serves as a laser-point to therapy billing, but also includes other nursing and ancillary services.

The new proposal is complex but is clearly aimed at unearthing the deeper details in the realm of mixed-case RUGs and how to categorize the nursing resources required to care for them. For example, where a RUG-IV consists of two case-mix-adjusted components (like therapy and nursing care), the proposal would create four different categories for a truer representation of the case mix. That, of course, means major changes to how case-mix and intensity of care are defined, the advanced proposed rule states.

CMS released the advanced notice on rule-making in order to garner comment on potential options for “revisiting certain aspects of the existing skilled nursing facility prospective payment system payment methodology.” The advance notice is scheduled to be published in the Federal Register on May 4, 2017. The comment period on the advanced notice ends June 24, 2017.

To comment electronically, click here and type in the regulation identifier number of 0938-AT17.  For other ways to comment, see page 2 of the advanced notice.

Topics: Clinical , Executive Leadership , MDS/RAI