You Are Here:Home/Resources/DNS Navigator/DNS Navigator Details
Directors of nursing services (DNSs) often take a largely hands-off approach to Medicare Part A coverage issues, says Suzy Harvey, RN-BC, RAC-CT, managing consultant at BKD in Springfield, MO. “In many facilities, DNSs more or less delegate the entire Medicare program to the MDS coordinator or the Medicare consultant. This ability to delegate is important because DNSs have such a demanding job. However, DNSs ultimately are responsible for all aspects of resident care. The MDS is a part of that, as are Part A skilled services.”
Consequently, DNSs still need to provide oversight—to be a member of the Medicare Part A team and to be aware of how well facility systems work by either auditing medical records or reviewing the results of delegated audits, suggests Harvey. “A DNS who just says, ‘The MDS coordinator handles that,’ could run into unexpected problems during medical review.”
“The implementation of the Patient-Driven Payment Model (PDPM) changed the payment system used for traditional Part A residents,” notes Harvey. “It did not change the coverage policies for skilled services.”
Therapy utilization will no longer be a payment driver under the Patient-Driven Payment Model (PDPM) in the Skilled Nursing Facility Prospective Payment System (SNF PPS), but skilled therapy services still have a key role to play. Liz Barlow, RN, CRRN, RAC-CT, DNS-CT, senior director of quality for RehabCare in Louisville, KY, offers five ways that directors of nursing services (DNSs) can work with the interdisciplinary team to get the most bang for their buck with therapy:
Under the Patient-Driven Payment Model (PDPM), resident outcomes will be key to avoiding medical review, said officials with the Centers for Medicare & Medicaid Services (CMS) during the August 14 Skilled Nursing Facility Quality Reporting Program (SNF QRP) training session, Patient-Driven Payment Model: What Is Changing (and What Is Not). Note: Find the session slides here.
The goal of PDPM is for SNFs to provide value-driven care, said officials. “Fundamentally, it comes down to a balance. A high-value and efficient provider is one that is able to achieve high-quality outcomes at low cost.”
CMS measures SNF quality of care in three main ways:
The SNF QRP;
The Skilled Nursing Facility Value-Based Purchasing (SNF VBP) program; and
The Five-Star Quality Reporting System on Nursing Home Compare.
Under the Patient-Driven Payment Model (PDPM) that goes into effect this October 1 for the Skilled Nursing Facility Prospective Payment System (SNF PPS), restorative nursing plays two key roles, just as it did under RUG-IV:
1. It is a qualifier for two payment classification categories in the nursing component of PDPM:
a. Behavioral Symptoms and Cognitive Performance, and
b. Reduced Physical Function.
Note: See the chart at the end of this article for an overview of restorative nursing’s role in the nursing component of PDPM.
2. It also can serve as the daily skilled service required to meet a skilled level of care for Medicare Part A patients (e.g., upon admission when skilled therapy isn’t medically necessary, in conjunction with skilled therapy that doesn’t meet the daily requirement, or after the patient is discharged from skilled therapy). Section 30.6, Daily Skilled Services Defined, in Chapter 8, “Coverage of Extended Care (SNF) Services Under Hospital Insurance,” of the Medicare Benefit Policy Manual offers insights into its role as a daily skilled service:
“In instances when a patient requires a skilled restorative nursing program to positively affect his functional well-being, the expectation is that the program be rendered at least 6 days a week. (Note that when a patient’s skilled status is based on a restorative program, medical evidence must be documented to justify the services. In most instances, it is expected that a skilled restorative program will be, at most, only a few weeks in duration.)”
The Fiscal Year (FY) 2020 Skilled Nursing Facility Prospective Payment System (SNF PPS) Final Rule updates the fee-for-service Medicare Part A payment rates using the new Patient-Driven Payment Model (PDPM) case-mix classification system effective October 1, 2019. On the payment side, the Centers for Medicare & Medicaid Services (CMS) made multiple small corrections, ranging from adjusting the market basket update to correcting the wage-index file.
However, the biggest changes that CMS finalized involve new MDS data submission requirements for Standardized Patient Assessment Data Elements (SPADEs) under the Skilled Nursing Facility Quality Reporting Program (SNF QRP) that will go into effect on October 1, 2020—just one year after PDPM implementation. But the changes don’t stop there. Directors of nursing services (DNSs) also need to prepare for a few PDPM policy revisions and updates to the Skilled Nursing Facility Value-Based Purchasing (SNF VBP) program.
Here are the highlights of the FY 2020 SNF PPS Final Rule that DNSs need to know about.
On April 24, the Centers for Medicare & Medicaid Services (CMS) made a series of changes to the Five-Star Quality Rating System on Nursing Home Compare. Now that directors of nursing services (DNSs) have that update under their belt, they can take the following steps to get a handle on the biggest surprises:
To access this article, please login or sign up for a membership.