To date, the accuracy of section GG (functional abilities and goals) hasn’t mattered from a payment perspective. Section GG doesn’t affect payment under the RUG-IV case-mix classification system, and the Skilled Nursing Facility Quality Reporting Program (SNF QRP) only penalizes providers financially for failing to meet the data submission threshold for required MDS data elements, including section GG items. In other words, completeness—not accuracy—is what allows providers to avoid the SNF QRP’s 2% payment cut every fiscal year.

As a result, many SNFs have relied exclusively on therapy to complete section GG, says Robin Hillier, CPA, STNA, LNHA, RAC-MT, president of RLH Consulting in Westerville, OH. “However, CMS always intended section GG to be a collaboration that includes both nursing’s perspective and therapy’s perspective. PDPM will require providers to make good on CMS’s intent because section GG will affect three of the five case-mix-adjusted PDPM payment components: nursing, physical therapy (PT), and occupational therapy (OT).”

A significant percentage of nursing homes don’t take advantage of their CASPER (Certification And Survey Provider Enhanced Reports) reports, says Carol Maher, RN-BC, RAC-MT, CPC, director of education for Hansen, Hunter & Co. PC in Vancouver, WA.

“Almost every week when I walk into a new facility and ask for some of their CASPER reports, no one can provide them,” she explains. “For example, I may ask, ‘What does your Skilled Nursing Facility Quality Reporting Program (SNF QRP) Review and Correct Report show?’ Or ‘Can you get me a copy of your MDS 3.0 Facility-Level Quality Measure (QM) Report?’ And it’s surprising how common it is for providers not to have even heard of the reports I ask for—or if they know what the reports are, they either don’t know how to obtain them or just never do.”

Both new and seasoned directors of nursing services (DNSs) should pay attention to CASPER reports, says Maher. “The DNS job is so difficult. Using these tools that the Centers for Medicare & Medicaid Services (CMS) provides can make it a little easier to know where to focus your resources.”

The MDS assessment schedule for the Skilled Nursing Facility Prospective Payment System (SNF PPS) will be radically simplified under the Patient-Driven Payment Model (PDPM), effective October 1. In the Fiscal Year (FY) 2019 SNF PPS Final Rule, the Centers for Medicare & Medicaid Services (CMS) estimated that the switch to only two required PPS assessments (i.e., the 5-day PPS MDS and the Part A PPS Discharge assessment) would result in each skilled nursing facility (SNF) saving approximately 188 administrative hours per year based on a single PPS assessment taking 51 minutes to complete. Note: CMS didn’t include the optional provider-driven Interim Payment Assessment (IPA) in these calculations.

“However, there is a lot of debate about how much time the changes to the PPS assessment schedule actually will free up once providers move from theory to practice,” says Robin Hillier, CPA, STNA, LNHA, RAC-MT, president of RLH Consulting in Westerville, OH.

October 1 will be here before we know it. And with that comes Medicare’s new Patient-Driven Payment Model (PDPM) for beneficiaries accessing their SNF Part A benefit. It seems like every day there is a new webinar being advertised to help you understand all of the ins and outs of PDPM. It is definitely a more complex system than the RUG-IV system we operate under currently. As we analyze data collected in our facilities, trying to understand where we stand in a PDPM world, there is one other thing to consider: your therapy contract.

For several years now, the Centers for Medicare & Medicaid Services (CMS) has been working to transform both payment and care delivery in the Medicare program. A key vehicle in the agency’s efforts is the Accountable Care Organization (ACO). 

Every nursing facility must have resident care policies and procedures for respiratory care and services, including tracheostomy care and suctioning, to avoid a citation under §483.25(i) F695 Respiratory/Tracheostomy Care and Suctioning. The care policies must be developed with the medical director, the director of nursing, and when appropriate, a respiratory therapist. The respiratory care policies and procedures must be consistent with professional standards, be comprehensive and person-centered, and address each resident’s goals and preferences. The care policies must be developed prior to admitting any resident with respiratory care needs.