AOTA Continues to be Concerned About Medicare SNF Proposal Lacking Safeguards for Provision of Medically Necessary Therapy

A new proposed Medicare rule could negatively affect occupational therapy practitioners working in skilled nursing facilities if implemented as is. The proposal includes a payment model without enough safeguards or a therapy threshold to require the provision of medically necessary therapy.

The Centers for Medicare & Medicaid Services (CMS) recently released its proposal for FY 2019 Skilled Nursing Facility (SNF) Prospective Payment System. The proposal includes a new payment model called the Patient-Driven Payment Model (PDPM) to replace RUG-IV on October 1, 2019. The new PDPM would rely on patient diagnosis and remove therapy minutes as a determinant of SNF payment.

The PDPM includes the following changes from the draft Resident Classification System, Version I (RCS-I) issued in 2017, among others:

• Separates the PT/OT component into two separate case-mix components;
• Removes cognitive status as a classification determinant for OT and PT components;
• Uses Section GG items to calculate the functional score;
• Adds an interim payment assessment to capture a change in resident classification; and
• Establishes a combined 25% limit on group and concurrent therapy for each discipline.

If implemented as is, AOTA continues to believe that OT practitioners could be significantly affected because it lacks enough safeguards for the provision of medically necessary therapy. AOTA will post an in-depth analysis soon and will submit comments by the June 26 deadline.

Read the CMS fact sheet and the proposed rule.