CMS Posts Proposed Changes to SNF PPS FY 2012

On April 28, 2011 CMS released  the Proposed Rule for updates to the SNF PPS system for FY 2012.  CMS has a 60 day comment period currently underway regarding these proposed changes.  The deadline to file a comment is June 27, 2011.  Harmony encourages SNF management and staff to read through the proposed changes and submit comments  addressing support or appeal for negating the changes.  The complete document can be accessed at the following link:

http://www.ofr.gov/OFRUpload/OFRData/2011-10555_PI.pdf 

The address for electronic or paper submissions are listed within this document, beginning on page 2.

Harmony summarizes several of the proposed changes:          

• Changes to the Medicare required assessment schedule.  
• Allocation of Group therapy minutes equally between participants.
• Limiting Group therapy to sessions with 4 patients (no less or no more).
• Plan of care for therapy must contain the rational for Group therapy. 
• EOT OMRA - any three day break in provision of therapy services requires completion of an EOT - no exceptions.
• New EOT Resumption assessment to be used when therapy resumes within 5 days of the EOT OMRA at the same RUG level. 
• Eliminate the distinction between 5 day and 7 day a week therapy programs in facilities for setting the ARD for EOT OMRA.   
• Therapy students will not longer require line-of-sight supervision.