This afternoon, the Centers for Medicare and Medicaid Services (CMS) released the Skilled Nursing Facility Prospective Payment System (SNF PPS) final rule for Fiscal Year (FY) 2012. The rule contains an 11.1% reduction in payments to skilled nursing facilities for FY 2012. This reduction is due to a recalibration of the case-mix indexes to account for increases in payment levels that were not anticipated by CMS after the revision of policies regarding RUG-IV, specifically the allocation of concurrent therapy minutes in the FY 2010 final rule.
In addition, the rule also finalizes CMS proposals regarding:
CMS defines group therapy as therapy provided simultaneously to 4 patients who are performing similar therapy activities. For therapists treating patients in a group setting, the full time spent by the therapist with these patients would be divided by 4 (the number of patients that comprise a group).
CMS discontinues the policy announced in the FY 2000 final rule's preamble requiring line-of-sight supervision of therapy students in SNF. Effective October 1, 2011, as with other inpatient settings, each SNF will determine for itself the appropriate manner of supervision of therapy students consistent with state and local laws and practice standards. CMS states that the student is viewed as an extension of the therapist therefore the policies regarding individual, concurrent, and group therapy as articulated in the RAI manual are still applicable.
CMS clarifies that an EOT OMRA must be completed if a patient goes 3 consecutive days without treatment. In addition, CMS finalizes its proposal to give SNFs the option to complete the EOT-R if therapy resumes in less than 5 calendar days.
Lastly, CMS finalizes its proposal to require a new assessment, the COT OMRA, to be completed every 7 calendar days to update current therapy provided to the patient, regardless of whether the patient has had a significant change in condition.
APTA is conducting a full analysis of the final rule and will provide a detailed analysis shortly. A copy of the proposed rule can be found at this link.