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 CMS Drive For Savings Seen In Latest MDS Revisions

​The latest revisions to the minimum data set (MDS) 3.0, effective from Oct. 1, 2011, are further proof that the Centers for Medicare & Medicaid Services (CMS) is putting into action what it has been saying for some time: The agency really wants to contain costs, says a top executive with therapy contractor Legacy Healthcare Services.

“These kinds of changes have to happen from the standpoint of CMS and will continue to happen as they work to find a way to tie the delivery of services to the value of those services,” says Ann Irwin, vice president of clinical programs and development for Raleigh, N.C.-based Legacy Healthcare Services.

The key now for everyone in the delivery of health care services is to document outcomes, which can then be used to show CMS the value of care being provided to residents and patients.

“As a therapy provider, we are focused on using objective, measureable information to provide outcomes data for what we do. It is essential to show you are showing cost-efficient services,” Irwin says.

She notes that the fiscal year 2012 MDS revisions were signaled well ahead of time by CMS, but are just part of the Prospective Payment System (PPS) world.

“At least since PPS came in 1998, we have dealt with changes almost every year in regard to reimbursement. These changes are fairly big, but folks learn how to adapt,” Irwin says.

The PPS for 2012 does alter a number of therapy rules, the most notably impacting the Change of Therapy (COT) Other Medicare Required Assessment (OMRA), she says.

The Oct. 1 revisions require the evaluation of rehabilitation service delivery seven days after the assessment reference date or COT to determine if the Resource Utilization Group (RUG) has been maintained. If the RUG is unchanged, no assessment is needed. If the RUG rehab intensity increased, the COT OMRA must document an increase in the RUG, but if there is a decrease, the COT OMRA must document a decrease in the RUG.

OMRA simply refers to an unscheduled assessment, like one to reclassify a resident from a Rehab RUG to a Rurse RUG or different rehab RUG.

Irwin says the most typical type of clinical therapy her company works with includes orthopedic cases like joint replacement, along with post-stroke recovery, and general medical conditions like recovery from heart disease.
Legacy Healthcare Services delivers contract therapy services to skilled nursing facilities, assisted living facilities, continuing care retirement communities, out-patient agencies, and home health agencies.
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