LeadingAge NY Comments on RCS-1

LeadingAge NY submitted comments to the Centers for Medicare and Medicaid Services (CMS) outlining our observations on the new Medicare Part A rate methodology being considered. Although no formal proposal has been made yet, CMS has developed an alternative to the current RUG-IV methodology that would significantly restructure how Medicare Part A nursing home rates are developed. CMS published an Advance Notice of Proposed Rule Making indicating that they intend to propose, as early as next year, that RUG-IV be replaced by the Resident Classification System (RCS-1).

We expressed support for the idea of tying payment more closely to objective resident characteristics but were wary of the ambitious implementation timeline contemplated, given the training and systems redesign it would require at the same time that a number of other major SNF initiatives are being implemented. We recommended that CMS take this opportunity to develop a SNF-specific wage index and suggested that locking in reimbursement for the entire stay based on a single five-day assessment could be problematic.

Our full comments are available here, and our summary of the RCS-1 methodology is available here.

Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841