Long-Term Care

Say goodbye to section T of the MDS

MDS 3.0 Insider, August 24, 2009

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The FY 2010 SNF final rule, which CMS released July 28, includes components that will change some facility processes related to therapy services and ultimately affect RUG classification. Effective October 1, 2010, CMS will eliminate section T of the MDS, introduce an optional start-of-therapy Other Medicare Required Assessment (OMRA), modify the assessment reference date (ARD) requirements for the end-of-therapy OMRA, and revise the reporting process for short-stay residents. Although the changes aim to increase the accuracy of payments to facilities, many providers are concerned about the financial pressures and increased workload these changes may cause.

Section T of the MDS is used to estimate how much therapy a resident will receive in the first 14 days of a SNF stay, which drives RUG classification. However, the Government Accountability Office found that “one-quarter of the patients classified using the estimated therapy minutes did not receive the amount of therapy they were assessed as needing,” according to the final rule. CMS’ decision to remove section T of the MDS will help prevent inappropriate RUG classification due to therapy projection and better align reimbursement with the actual services provided.

Some providers are concerned that the elimination of section T could mean that data would not be captured for days when therapy services were actually provided. CMS addresses these concerns by introducing an optional start-of-therapy OMRA with an ARD five to seven days from the start of therapy. This optional OMRA would reclassify the resident into the appropriate rehab RUG and payment under this RUG would begin on the day therapy started. CMS will also require that facilities complete an end-of-therapy OMRA within one to three days after all therapy is discontinued, instead of the current requirement to complete this assessment within eight to 10 days after all therapy ends. This will prevent facilities from getting paid a higher rehab RUG for days when no rehab was provided.

CMS received comments that the additional start-of-therapy OMRA and changes to the ARD of the end-of-therapy OMRA would require facilities to complete more assessments in a shorter amount of time, thus increasing the workload of SNF staff. To address these concerns, CMS will shorten both of these assessments to only include the necessary information. 

In the SNF final rule, CMS also calls to revise the reporting the rehab RUG classification process for short-stay residents, which are defined as residents who are discharged on day 8 of the SNF stay or earlier. This revised process will calculate the rehab RUG for short-stay resident by using items from the MDS 3.0, including the number of therapy minutes provided, date of admission, date therapy started, ADL level, and the ARD. According to the final rule, classification into rehab RUGs for short-stay residents “will be based on the average daily minutes of therapy provided,” which are as follows:

  • Average daily therapy minutes are between 15-29 minutes = Rehabilitation Low category (RLx)
  • Average daily therapy minutes are between 30-64 minutes = Rehabilitation Medium category (RMx)
  • Average daily therapy minutes are between 65-99 minutes = Rehabilitation High category (RHx)
  • Average daily therapy minutes are between 100-143 minutes = Rehabilitation Very High category (RVx)
  • Average daily therapy minutes are 144 or greater =  Rehabilitation Ultra High category (RUx)

Even though CMS does not believe that these changes will produce financial pressures and have taken steps to ensure they do not result in an increased workload, these components of the final rule will modify many facility processes related to therapy services and SNFs should ensure their staff are well trained and prepared to adapt. 

To view the FY 2010 SNF final rule, visit the Resources page on MDSCentral.


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