Ask Medicare to Revise Proposed SNF Payment Model Using This Template Letter

06/04/2018

CMS recently issued the proposed rule for the FY 2019 Skilled Nursing Facility (SNF) Prospective Payment System (PPS). This proposal includes a revised case-mix methodology called the Patient-Driven Payment Model (PDPM) that will dramatically change the way payment for SNF services, including occupational therapy services, are determined. Most significantly, the PDPM would remove therapy minutes as a determinant of payment and create a payment model based on resident clinical characteristics. The PDPM is a revision of last year’s draft Resident Classification System, Version I (RCS-I). CMS is proposing for the PDPM to go into effect on October 1, 2019.

AOTA’s primary concern with the PDPM is that patients who require medically necessary occupational therapy may not have access to occupational therapy services because of the model design. Concerns include:

The PDPM does not reference cognition or feeding/swallowing in the occupational therapy payment component. This exclusion could inappropriately limit occupational therapy practitioner’s role in addressing these areas.
The PDPM does not include co-morbidities in determining the OT or PT payment components.
PDPM implementation could be very confusing and burdensome. CMS should set forth a clear transition period.
CMS should also finalize the proposed combined 25% limit on group and concurrent therapy for each discipline. AOTA will comment on the group therapy definition and documentation requirements in this area. Ultimately, clinical judgment must be the deciding factor in determining the appropriate type of therapy for each individual patient.
On the positive side, CMS proposes to require reporting of therapy mode and minutes at discharge in order to monitor skilled therapy utilization. CMS must adopt its proposal in the final rule to assure access to medically necessary occupational therapy.

Read more in the CMS fact sheet and the proposed rule.

Call to Action—What Can You Do?

Comments are due online by June 26, 2018. You can submit comments to CMS, too! There is power in numbers and you can voice your concerns directly to CMS. AOTA has developed a Template Letter (download Word doc) to assist practitioners in submitting comments online to CMS by June 26. We encourage you to customize the letter with your own concerns and specific examples of the types of patients you treat whose service need may not be appropriately addressed by the PDPM. We encourage you to draft your letter in Word prior to going to the submission website.

Download the Template Letter

Once your comment letter is ready for submission, you may submit electronic comments on this proposed regulation:

Go to https://www.federalregister.gov/documents/2018/05/08/2018-09015/medicare-program-prospective-payment-system-and-consolidated-billing-for-skilled-nursing-facilities
Click on the green ‘‘SUBMIT A FORMAL COMMENT’’ box
Enter your comments into the comment box by copying and pasting from the document you have drafted in Word or personalized from the Template Letter (download Word doc). Or, you may attach a document by choosing Upload File (be sure include the date and your name in the document).

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