RCS-1 & Changes to RUGs

I've had some good conversations around what CMS is saying and what they're not saying when it comes to changes in RUGs. A lot of the conversation has been around the table below. 

It's confusing for several reasons. First, if you're looking at the table on the federal register, they did not include the header that was present in the technical document. The middle column is the percentage of stays at that RUG level and the third column is the change in PPD for those patients if RCS-I had been in use. 

Keep in mind that RCS-I was developed using 2014 data. This table is saying "We took (almost) every Med A SNF resident from 2014 and calculated the total payment that would have been paid had we been using RCS-I". That means the patient arrived with the exact same conditions and had the same length of stay. If length of stay happens to go down with this new system, then the overall payment will too.

The table is really of very limited usefulness because of this. You can make estimates based on the RUG distribution in you facility. (I even made a calculator to make that easy.) However, each patient really will get RUG levels that are much more customized. (remember there are 4 RUG levels per patient in RCS-I.) The level of therapy provided will absolutely change and that could have an effect on the length of stay.

I think the main point of this table is to send the message that "You will make less money if you're doing a lot of UH."