How will the October CMS changes affect you?

LaVie Rehab commenced our strategic planning for the upcoming CMS changes in December 2009. We knew we needed to proactively address the proposed changes with implementation of pilot practices in over 20% of our facilities. Comprehensive training has been completed for each Director of Rehab and will continue as we approach October 1. Our training has also been a collaborative effort with our SNF colleagues so that we optimize our success under the CMS regulatory changes.

What are the major CMS changes?

A revised MDS — MDS 3.0 replaces MDS 2.0. Specific therapy-related changes include:

• Coding of Therapy Minutes based on delivery mode
• Section T is eliminated, so that no projection into RH or RM can occur
• Start of therapy OMRA is a new optional unscheduled assessment
• End of Therapy OMRA 1-3 days (vs. 8/10) is a new mandatory assessment
• Short Stay Assessment is a new unscheduled assessment designed for those residents who are discharged from the SNF before day 8 of a skilled stay
• ADL Scoring
• Scheduled 5, 14, 30, 60, 90 day assessments, with use of grace days as appropriate, will continue

The MDS 3.0 will capture start and end dates of therapy in Section O for each discipline. Both a therapy RUG and a non-therapy RUG may occur in a single patient’s stay.

From the MDS, a new RUGS IV grouper system creates 66 categories as opposed to the current 53.

RUG IV  
There are no changes to current rehab category requirements, including minutes of therapy and disciplines involved over the course of the days of the week. However there are changes to the way in which delivered minutes are counted on the MDS 3.0 and the RUG level will be set using the following new definitions.

Individual services are provided by one therapist or assistant treating one resident at a time – this definition remains unchanged. Individual treatment time is reported under individual CPT codes. 100% of direct treatment minutes are reported on MDS. 100% of reported minutes count towards the RUG category

Concurrent therapy is the treatment of 2 residents at the same time, when the residents are performing two different activities in line of sight of the therapist or assistant. Concurrent treatment time is reported under individual CPT codes. One hundred (100) percent of direct treatment minutes are reported on MDS for each patient participating. Fifty (50) percent of reported minutes count towards the RUG category. In the event that three patients are treated concurrently, NONE of the minutes will be counted towards a RUG category for any patient.

Group therapy is the treatment of 2-4 residents (regardless of payer source), performing similar activities and supervised by a therapist or assistant who is not supervising any other individuals. Group treatment time is reported only under the group treatment CPT codes (97150/92508). One hundred (100) percent of group treatment minutes are reported on the MDS for each patient in the group. Twenty five (25) percent of each discipline’s weekly minutes will count towards the RUG category.

How do we manage under the new regulations?
LaVie Rehab’s best practices include specific protocols covering admissions, evaluations, scheduling, treatment and discharges.
Point Of Service Documentation, using our licensed “SMART” software and state of the art technology for documentation and billing, enhances our capability to provide the highest quality resident care.

Our new staffing/scheduling program is called “LaVie Achieve,” which is a program that will provide a higher level of work/life balance for our teammates while accommodating CMS changes. LaVie Achieve allows each therapy team to:

• Determine a “flexible” work schedule option in achieving a seven day per week service model
• Stagger work hours
• Enhance the opportunity to structure the work day
• Assist in providing diverse treatments, including groups

There are obvious benefits to this program, which include:

• Increased one-on-one time with patients
• Increased weekend services
• Increased timely completion of evaluations
• Increased resident participation and satisfaction
• Increased teammate satisfaction
• Increased training opportunities
• Increased therapists' knowledge of PPS
• Increased time for program development and rounds
• Increased effective use of staff
• Optimized RUG’s Utilization
• Increased marketability of programs and services
• Increased proactive vs. reactive scheduling approach

As you can see, we at LaVie Rehab provide a supportive, resident and employee-focused environment in which to enhance your career. We pride ourselves on being a step ahead of the competition and delivering high quality training products that take the mystery and uncertainty out of regulatory and other changes which impact our residents and our workforce.