Today, a member of the Technical Expert Panel (TEP) involved in discussing CMS’ proposed case mix pre-rule shared with Post-Acute Advisor the top three concerns discussed among other TEP members and advocacy groups. Topics are as follows:
#1. Protections to ensure beneficiary access to care. Providers and beneficiaries are seeking more clarifications into system safeguards which will monitor access to care and service delivery. The use of a single MDS assessment at the start of care, in addition to significant change and end of care assessment could potentially limit the ability of RCS-I to fully measure the level of services being provided.
#2. Coordination with payment refinements, including those required by the Improving Post-Acute Transformation (IMPACT) Act.
#3. Potential restrictions on the use of group and concurrent therapy. The proposed rule suggests limiting concurrent and group therapy to 25%, which would create a blanket policy that places an arbitrary restriction on the amount of time spent in delivering therapy in a particular mode of therapy (e.g. group, individual, concurrent). This method is not based on the unique needs of the resident and his/her clinical presentation.
The comment deadline for the advance notice of revisions to case-mix methodology is open until August 25.