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 Providers Assess Positive Changes CMS Proposes for Group Therapy Definition

As the long term and post-acute care (LT/PAC) profession continues to assess the Fiscal Year 2020 Skilled Nursing Facility (SNF) proposed payment rule released by the Centers for Medicaid & Medicare Services (CMS) on April 19, one leading expert tells Provider why the plan’s 2.5 percent net payment increase was just one piece of good news from the proposal.

On payment, CMS wants SNFs to receive a net 2.5 percent increase after all required deductions in FY 2020, which on an aggregate basis sums to $887 million.

CMS also proposes to expand the definition of group therapy starting on Oct. 1 with its new payment plan, the Patient Driven Payment Model (PDPM). This would mark a major step forward for providers, according to Daniel Ciolek, associate vice president, therapy advocacy for the American Health Care Association (AHCA).

Currently, a group must be four people to be called group therapy. But, LT/PAC providers believe this definition restricts the use of group therapy, and CMS agreed by stating in the proposed rule that starting with the new PDPM a group can consist of between two and six patients. 

Ciolek says first and foremost, the change would allow the therapist the autonomy to provide the most appropriate care based on the resident’s current care needs and evidence-based research. “Second, the standardization across post-acute provider settings for patients with similar characteristics represents an important step in achieving the aspirations of the IMPACT Act in reducing care variability and outcomes across post-acute care settings,” he says.

IMPACT refers to the Improving Medicare Post-Acute Care Transformation Act of 2014, a law that seeks to change and improve Medicare’s post-acute care services and how they are reported. 

Other than the proposed revision in the definition of group therapy in the proposed rule, the most significant CMS clarifications related to therapy services that have already been furnished via the frequently updated PDPM frequently asked questions on the CMS PDPM website, Ciolek says.

He adds that the relatively low number of changes being made to PDPM is also a positive for providers that are preparing for the transition this fall.

“The lack of policy volatility is helpful at this time as most providers have already initiated RUGs [Resource Utilization Groups] to PDPM transition activities, including self-assessment, gap analysis, planning, and training, none of which will require a significant alteration based upon this NPRM [Notice of Proposed Rulemaking],” Ciolek says.         

There are some other minor changes to PDPM that AHCA is still evaluating, particularly in situations like how CMS intends to approach updating PDPM policies via regulatory or sub-regulatory processes, depending on whether a change is deemed substantive or non-substantive. 

“For example, CMS proposes to provide routine updates to the PDPM ICD-10 [International Classification of DiseasesTenth Revision, Clinical Modification] code mappings and lists by updating tables on the CMS PDPM website, while more substantive changes would be proposed through rulemaking,” he says.

Overall, the assessment of the proposed rule turns on the fact that CMS is clearly making the final turn toward the implementation of PDPM on Oct. 1 and that the limited scope of proposed changes in this NPRM indicates that “CMS is ready to roll,” Ciolek says. 

“AHCA has been providing extensive PDPM preparedness training to our members nationwide, and we are encouraged by the energy and attentiveness our members have demonstrated in working toward making this a successful transition,” he adds.     

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