Medicare Compliance & Reimbursement

Long-term care providers should keep their three-hole punch handy. The buzz from the recent annual RAI Coordinators Conference suggests that the Centers for Medicare & Medicaid Services may already be busy refining parts of its August 2003 update to the Long-Term Care Facility Resident Assessment Instrument User's Manual. Attendees at this year's conference focused on the August 2003 update, seeking further clarification from CMS on a handful of reimbursement-sensitive changes. Attendees at the annual conference of the American Association of Nurse Assessment Coordinators, held in Las Vegas this month, also sought to clarify the August manual clarifications. To keep RUGs right and quality indicators on track, skilled nursing facilities should be familiar with the following CMS clarifications: SNFs are no longer required to keep copies of each resident's MDS assessments in his or her chart for 15 months. According to the update, the documents must be kept in a central location that is "accessible to all professional staff members (including consultants) who need to review the information in order to provide care the resident." SNFs should code skin tears/shears caused by injury at M4 unless pressure contributed to the wound. This change should improve quality indicators numbers for some facilities. SNFS should look for further clarification from CMS on the topic of coding IV drugs or blood transfusions provided only during chemotherapy or dialysis, predicts Ruta Kadanoff of the American Association of Homes and Services for the Aging. The update stipulates that such IV drugs and blood transfusions provided during chemotherapy are not to be coded under the respective items: K5a (parenteral/IV), P1ac (IV medications) and P1ak (transfusions). This change is reimbursement sensitive, according Mary Pratt, a specialist with CMS' Center for Beneficiary Choices, Quality Measurement and Health Assessment Group, speaking at the AANAC meeting. In a change that's good news for calculating RUGs, providers now have more freedom when coding physician visits and orders. The update eliminates the restriction that to be counted at P7 or P8, a physician assistant or nurse practitioner could not be employed by the facility. The update also stipulates that providers can count visits by a "clinical nurse specialist" working in collaboration with a physician. Though CMS won't reconsider claims affected negatively by the admitted error in the December 2002 version of the RAI Manual regarding coding physician visits and orders, providers do have recourse if they find that they've under-coded by their own error. Simply modify the PPS assessment and submit an adjusted bill. Such adjustments are allowed on claims no older than 120 days from the through date of the UB92. SNFs should use actual weight when calculating for item K3, a change that could affect quality indicators. Confusing is the fact [...]