Concurrent Therapy

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How the SNF PPS Final Rule Will Affect Therapy Providers on ADVANCE for Speech-Language Pathologists and Audiologists

How the SNF PPS Final Rule Will Affect Therapy Providers on ADVANCE for Speech-Language Pathologists and Audiologists.

Leigh Ann Frick, PT

Posted on: August 21, 2011

The post-acute therapy world suffered a major setback on July 29 when the SNF PPS Final Rule for fiscal year 2012 was released.

The implementation of Minimum Data Set (MDS) 3.0 and RUGs IV last fall modified minute recording, requiring individual, concurrent and group minute delineation. It also changed the definition and allocation of concurrent minutes.

Concurrent therapy was defined as two residents who are not performing the same or similar activities at the same time, regardless of payer source. Both must be in the line of sight of the treating therapist or assistant.

The minutes would be divided by two, allowing a therapist/assistant to only get credit for half of the minutes delivered to each resident. CMS recognized concurrent therapy as a valid method of service delivery but believed it was not being utilized properly.

This change penalized everyone, creating the need for increased staff hours to deliver the same amount of therapy prior to Oct. 1, 2010. CMS made no changes to the parameters surrounding group therapy until now.

In the Final Rule for Oct. 1, 2011, CMS changed the definition of group therapy to “the treatment of four residents, regardless of payer, who are performing similar activities and are supervised by a therapist or assistant who is not supervising any other individuals.”

The limitation of 25 percent per discipline per week still applies, but the minutes provided in a group setting will be divided by four. If four patients are in a group for 60 minutes, each will have only 15 of the 60 minutes apply to their rehab RUG category or count as “reimbursable therapy minutes” (RTM). (Click link above for more)

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OIG urges CMS to take action in light of skilled nursing overpayments | News | ArtIcles/News | Long-Term Living Magazine

OIG urges CMS to take action in light of skilled nursing overpayments | News | ArtIcles/News | Long-Term Living Magazine.

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Providers still adjusting to new Medicare rules – McKnight’s Long Term Care News

Providers still adjusting to new Medicare rules – McKnight’s Long Term Care News.

The switchover to MDS 3.0 and RUG-IV may have happened months ago, but long-term care and therapy providers say they are still honing their policies and practices… 

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June 23 CMS Call on RUGs-IV Medicare Payment System

This first conference call on SNF PPS will focus on an overview of SNF PPS. CMS will provide the history of RUGs and review the requirements of SNF coverage. In addition, CMS will discuss the look back implications for several MDS 3.0 items, the impact and coding of concurrent therapy and a brief discussion on group therapy.

Moderator Information
Moderator: Geanelle Griffith, Health Insurance Specialist
Organization: Centers for Medicare & Medicaid Services
Presenter Information
Speakers: Sheila Lambowitz, Director, and Ellen Berry, Health Insurance Specialist
Organization: Centers for Medicare & Medicaid Services

Register Here: http://www.eventsvc.com/palmettogba/register/3e3c0157-011c-46b7-9ebd-7703f3515599

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Regulators to start conference-call series to teach new nursing home payment system – McKnight’s Long Term Care News

Regulators to start conference-call series to teach new nursing home payment system – McKnight’s Long Term Care News. – Providers with questions about the new nursing home payment system will be able to take part in a series of three training conference calls, beginning later this month, an official with the Centers for Medicare & Medicaid Services announced Thursday. The first will be held at 1:30 EDT on June 24 and deal with concurrent therapy, look-back periods and ADLs (activities of daily living).

“We didn’t want to get left behind so we’re also developing training programs,” said CMS’s Sheila Lambowitz during the SNF Open Door Forum conference call. She was referring to payment aspects of the new MDS and resource utilization group systems that will be used starting Oct. 1. “We’re planning to have three calls to talk about differing parts of the payment system.”

Registration information should be forthcoming from CMS either today or Monday, she explained. Interested parties will have to register to get a call-in phone number to participate, she emphasized. The other two calls are tentatively scheduled for Aug. 5 and 23. The content of those will be based on questions received, she added.

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What is the issue with Concurrent Therapy?

by: LTCREHAB

You may have heard that the Centers for Medicare & Medicaid Services (CMS) is closing the Concurrent Therapy loophole on October 1, 2010?  What is Concurrent Therapy: some therapy departments (managed by in-house or contract therapy companies) have relied on the use of concurrent therapy: “concurrent therapy is the practice of one professional therapist treating more than one Medicare beneficiary at a time — in some cases, many more than one individual at a time”. Concurrent therapy is distinguished from group therapy, because all patients are not on common skill development and are working on different goals and task. In a group therapy setting the patients are working on common skill development and tasks. In a group setting the ratio of participants to therapists may be no higher than four to one.”

CMS has further stated “A beneficiary who is receiving concurrent therapy with one or more beneficiaries likely is not receiving services that relate to those needed by any other participants. Although each beneficiary may be receiving care that is prescribed in his individual plan of treatment, it is not being delivered according to Medicare coverage guidelines: that is, the therapy is not being provided individually, and it is unlikely that the services being delivered are at the complex skill level required for coverage by Medicare.”

The new MDS 3.0 regulations that go into effect October 1, 2010, state that concurrent therapy of two (2) patients at a time will be allowed, concurrent therapy must also be documented separately (on the MDS) from the individual one-on-one and group therapy time.

So what is the concurrent therapy loophole? Some therapy departments (in-house and contract managed) transitioned from one-on-one therapy to “concurrent” therapy, under this method one professional therapist works with multiple patients on different therapy tasks at the same time, but they still bill Medicare as if each patient received 100% of the therapist’s attention. For example, SNF Medicare reimbursement rules have allowed a therapist treating four patients concurrently during the course of one hour to bill Medicare for four full hours of therapy. CMS reports that more than a quarter (28.26%) of therapy provided in SNFs is now concurrent. CMS will close this loophole when it implements the MDS 3.0 revisions to Medicare by requiring allocation of concurrent therapy time and by limiting concurrent therapy to two patients.

Concurrent therapy scenarios:

…a therapist treats 16 residents in the morning over a 4 hour period by providing therapy services “concurrently” four residents at a time….

…a therapist treats all residents concurrently and record the total minutes for all patients. For instance, the therapist provides 1 hour of concurrent therapy to four patients who are working on different goals and record 60 minutes of therapy for each.

Things to consider….

  • Are the residents receiving appropriate care?
  • How can their individual needs and goals be effectively and consistently addressed in the above scenarios?
  • How will therapy departments that have high utilization of concurrent therapy adapt to the new rules and regulations of concurrent therapy?
  • If a multi-facility organization has a high utilization of concurrent therapy, for them to maintain the same level of therapy under the new regulations how many more therapist will they have to hire?
  • Would not true “One-on-One” therapy be the best for the patient, therapist and provider?
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� RUG-IV May Require Revamping Case Management Strategies

� RUG-IV May Require Revamping Case Management Strategies. –posted on 16. May, 2010 by Editor in Surveys & Compliance

Home therapy visits could help achieve targeted outcomes under RUG-IV.

RUG-IV will only allocate half of a resident’s concurrent therapy minutes toward placement in a rehab RUG category. And the industry will take some time to figure out if having to split the minutes of concurrent therapy will “produce fallout for facilities coding concurrent minutes,” says Elisa Bovee, OTR/L, director of education and training for Harmony Healthcare International in Topsfield, Mass. Bovee predicts, however, that facilities will “steer away” from providing the modality.

Instead, facilities that have been providing concurrent therapy may use more group therapy — “especially facilities with an influx of admissions and not enough therapy staff to manage it,” she says.

“One case management strategy — if clinically appropriate for the patient — is to move to more group minutes … to meet the patient’s needs and also get in all the therapy minutes. Patients in group therapy are all performing a similar activity,” counsels Bovee.

Providing more rehab therapy home visits to Part A patients can also help achieve therapy outcomes and ensure discharge safety. For details, read “Rehab Therapy Home Visits Can Be the Ticket to Improving Discharge Safety” in MDS Alert, Vol. 8, No. 4,  available online. Source: http://longtermcare.inhealthcare.com/

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Healthcare Reform Will Impact Long-Term Care

Healthcare Reform Will Impact Long-Term Care –  (for full article click link to the left ) … One of these amendments awaiting a final vote is an amendment to delay the implementation of Resource Utilization Group, Version Four (RUG-IV), by a year. RUG-IV was originally scheduled to be implemented alongside the MDS 3.0 in October, but the amendment to the healthcare bill will not allow RUG-IV to be implemented before October 1, 2011.

However, the amendment will still implement the MDS 3.0, concurrent therapy adjustment, and changes to the look-back period to ensure that only services provided after skilled nursing facility admission are counted toward RUG placement on October 1 of this year.

“The RUG-IV delay is not certain yet, but we will know more as the budget reconciliation process unfolds and expect an answer within the next few days,” McCarthy says. “In my opinion, the RUG-IV delay is not a cost saver, and that a delay in the implementation of RUG-IV is unlikely, but we don’t have any concrete information at this time.”

McCarthy says long-term care faces challenges, but she is hopeful that it will continue to adapt.

“In my opinion, reform will be a hurdle for long-term care facilities and providers. While there will always be a need for nursing homes, healthcare reform does ultimately encourage greater usage of home care services or other residential options,” McCarthy says. “But overall, this bill, and the spirit with which it was written, is good for everyone, because its main goal is to increase the number of insured substantially and improve both quality and access to care. The long-term care sector has proven their adaptability in the past, and I am certain we will see that in these changing times as well.”

MacKenzie Kimball is an associate editor in the long-term care market at HCPro. She writes PPS Alert for Long-term Care and manages MDSCentral.

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AAHSA – Frequently Asked Questions On RUGs IV (Therapy)

Frequently Asked Questions On RUGs IV. – FAQs:

  • In Chapter 3 of the Resident Assessment Instrument (RAI) manual, CMS discusses concurrent therapy as no more than two (2) residents per “therapist or “therapist assistant.”  Where can I find a reference to this rule?

Answer: A reference to this new rule is available on the FY 2010 SNF PPS final rule (74 FR 40315ff). The limitation of concurrent therapy is to only two residents at a time, set to become effective upon the implementation of RUG-IV (i.e., as of FY 2011).

  • Would therapist provided by “aides” be allowed to be counted in the total number of therapy minutes delivered to the resident?

Answer: No. Therapy aides are not equivalent to therapy assistants. Therapy assistants receive education specific to that discipline, either physical therapy or occupational therapy, while there are no standards for therapy aides. In chapter 15 of the Medicare Benefit Policy Manual, Pub. 100-2, (section 230) qualifications for therapists, assistants and aides are discussed. In addition, in chapter 3, section O of the Resident Assessment Instrument (RAI) manual, CMS states that therapy aides may not provide skilled services (pg. O-16).

Source: American Association of Homes and Services for the Aging http://www.aahsa.org