In a recent CEU I showed the CMS generated projections of facility-level Part A revenue changes. A question that came up was "How do we prepare for a large decline in Part A revenue?" I will admit that my answer wasn't very good. Fortunately, I got called out on it by one attendee in the feedback.
Let me see if I can redeem myself a little. Here are some things to consider if you've just gotten bad news about where your Part A revenue might be heading.
- Take a good hard look at your nursing documentation. Right now it's easy to slack on documentation: once therapy picks up a patient, we get a therapy RUG. It's easy to overlook other nursing items. RCS-1 will punish you if you do that. Starting firming up your documentation procedures now. Everything you miss will cost you later.
- Take a hard look at respiratory therapy. If it's clinically appropriate, respiratory therapy for 15 minutes a day all 7 days of the first assessment will put a patient in the special care high RUG. (Obviously you'd use day 7 for the 5 day assessment.)
- ADL Scoring: This one applies with or without RCS. Don't slack on ADL training. Do it persistently and do it well. Quarterly is almost enough. Get a good program or a good trainer or both. The odds are very high that you are doing work that you are not being reimbursed for.
- Optimize other payers, especially Medicaid if you have any. Learn everything you can about how you are reimbursed with other payers. Make sure the plans you accept are being managed properly. Evaluate each payer monthly. Make changes as needed.
Also, the CMS predictions may not mean what we think they mean:
- The data is from 2014. Has your Med A caseload changed in the last 3 years? For a lot facilities, Med A census is dropping due to bundled payment. If your caseload has dropped (or increased) then the CMS estimate could be way off.
- Not all of the change in revenue is coming out of your pocket. If you are doing a lot of UH, and let's be honest, if CMS is predicting a reduction in your Part A pay, you are probably doing a lot of UH, then some of the reduction in your pay is coming from money that you are currently paying to therapy. That's not good news for therapy, but misery loves company.
- RCS could change. The latest revision included significant changes in the way SLP ADLs are processed. We can't be sure that more changes aren't on the way. We can't even be sure yet that it will ever be implemented.
A wise use of your time and money would be to optimize your current documentation with a specific focus on ADL scoring. Think of metrics that matter for you and track them at least monthly. Make sure everyone knows what you consider important and how they're doing. Regardless of RCS, this will help you to improve your financial situation which will help you weather whatever storm CMS comes up with.
Thank you CEU attendees! You got me thinking!