News, Skilled Nursing Facility

CMS still seeking feedback on RCS-1

During their SNF/LTC Open Door Forum call yesterday, CMS announced that, although the comment period for an advanced notice of proposed rulemaking (ANPR) published in May officially closed this August after receiving more than 200 comments, the agency encourages providers to continue submitting feedback by sending comments, questions, or concerns to CMS’ email inbox at

The ANPR proposed replacing SNF’s current nursing case-mix model, RUG-IV, with a new model, RCS-1 (Resident Classification System), in order to eliminate therapy overutilization due to the monetary incentives that currently exist under the RUG-IV model.

The agency stated that they do not currently have plans in place to publish comments in a Q&A or other format, but that they will “meet with leadership” to determine if this a route that makes sense for them to take. Another commenter on the call recommended that CMS conduct a demo of the RCS-1 model, voicing concerns that the model will play out differently when applied to real-life situations versus statistical studies that have been conducted so far. CMS officials responded that there are no plans in place, but that this idea is under consideration.

The agency also disclosed that another widespread concern from commenters is that providers will be supplying less therapy as a result of the RCS-1 model, a consequence that is also being reviewed.

The clinical and technical eligibility requirements for skilled care coverage in a SNF are unchanged under the proposed system. Changes implemented by the RCS-1 model include:

  • Where once therapy days and minutes served as the primary reimbursement driver, now in RCS-1, therapy may or may not be an intervention listed in the care plan.
  • The PPS MDS assessment schedule is reduced significantly to requiring just a five-day assessment, a significant change assessment if needed, and a discharge assessment. The five-day MDS assessment will determine payment for the entire skilled stay unless a significant change assessment is submitted. It’s essential to note that the OBRA MDS assessment requirements do not change, and that RCS-1 is only impacting Medicare FFS.
  • Some of the initial responses to RCS-1 suggested the role of the MDS would be devalued; however, the MDS will continue to drive the care for your long- and short-stay population under the RCS-1 model, as well as impact five-star quality measures, survey areas of focus, and Medicaid reimbursement in many states. RCS-1 reimbursement is almost exclusively being driven by resident characteristics data from the MDS. Now, more than ever, the MDS is the care, quality, and reimbursement driver for SNFs.

Officials further reminded providers to submit their PBJ staffing data for the July 1 – September 30 quarter by November 14. Providers with late submissions will have their overall staffing and registered nurse staffing ratings suppressed for the December 2017 Nursing Home Compare update. Eventually, CMS will create a staffing measure, but the agency has not yet decided how this measure will be calculated.

The majority of the changes that will occur with the implementation of RCS-1 are based on claims history and MDS data submitted. In order to understand and prepare for this shift, providers will need to learn how to achieve quality outcomes and higher reimbursement under a system that will offer different incentives.

Join Maureen McCarthy, BS, RN, RAC-MT, QCP-MT for a 90-minute webinar on Tuesday, January 16, 1:00-2:30pm, ET, as she dives into the new payment system and reviews the steps providers need to take to achieve higher reimbursement. Attendees will also learn how to use the new case mix methodology of resident classification system and the new ADL scoring.

At the conclusion of this program, participants will be able to:

  • Prepare for the shift to an episode-based payment system, and understand how to succeed post-shift by aligning incentives to optimize revenue and identifying clinical indicators to achieve higher reimbursement
  • Explain the new case-mix methodology of RCS-1
  • Explain new ADL scoring, clinical classification categories, and groupings called “condition categories”