In early August, the Centers for Medicare and Medicaid Services issued a final rule impacting rules and reimbursement for Skilled Nursing Facilities effective October 1, 2014. Of particular interest to RehabCare – and our parent company, Kindred – was the ongoing discussion of the development of a new methodology for paying for therapy services received in the SNF. During the public comment period prior to the issuance of the final rule, we took the opportunity to articulate our support for “an approach to reforming payments for therapy services provided in SNFs that preserves access to medically necessary services for Medicare patients, better aligns clinical need with services delivered, develops adequate controls and safeguards to ensure appropriate therapy utilization, and provides short-term stability for providers.” Within our comments we also urged CMS to actively engage stakeholders throughout the entire process. Specifically, we offered to participate in providing clinical and policy technical support for development of a new payment model. We suggested that this could be accomplished through Technical Expert Panels (TEPs) or a pilot. CMS’ Reaction Within the final rule, CMS indicated that all of the public comments they received on the development of the new payment methodology for therapy provided in SNFs supported the agencies’ research effort. They took note that some of the input they received strongly supported “input from stakeholders on how best to revise the current therapy payment model.” CMS stated that providers can continue to provide input on the issue outside the rulemaking process to SNFTherapyPayments@cms.hhs.gov. The agency also affirmed that they “plan to solicit feedback through more formal avenues such as a technical expert panel in the near future.” In terms of the timing for continued development and implementation of a new payment model, CMS said there is no clear timeline at this time. In the final rule, the agency agreed with the provider input they had received, that the process had “to ensure that any change to the current therapy payment model addresses any concerns with the existing model, provides the proper incentives to treat patients in the most appropriate and efficient way, and provides sufficient time for providers to understand and prepare for implementation of such a model.” Next Steps We were pleased with CMS’ reasoned approach to refining the payment model for therapy services provided in SNFs. We look forward to working with CMS and other policy makers as the process continues. We will provide updates as they are available.
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