On Monday, June 27, APTA submitted comments to the Centers for Medicare and Medicaid Services on the Skilled Nursing Facility (SNF) Fiscal Year (FY) 2012 proposed rule. In the proposed rule, CMS seeks to make significant payment cuts to SNF payment amounts and to substantially revise the provision of group therapy, the completion of therapy assessment requirements, and policies governing student supervision.
In its comments, APTA recommended that:
Concerning the therapy assessment requirements, APTA seeks better flexibility and less redundancy for SNFs’ requirements to complete Other Medicare Required Assessments (OMRAs) for Start of Therapy (SOT), End of Therapy (EOT), End of Therapy-Resumption (EOT-R), and Change of Therapy (COT). APTA specifically called for withdrawal of the proposal for COT OMRAs, requesting instead further analysis of the situations that CMS raised in the proposed rule to come up with a more appropriate and less burdensome requirement.
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