OIG Issues Report of Most Recent Study on SNF Therapy Billing

According to the OIG report, the study reflects that facilities utilize the new assessments instituted by CMS differently depending on whether there is an increase or a decrease in the amount of therapy provided.   This is a result of the inherent nature of the rules for the assessments, since when the assessment rules were promulgated they allowed for an optional completion of some of those assessments if certain conditions were met.   Facilities have simply followed the rules as they were written.  According to the OIG, the practice currently followed when completing the assessments resulted in “costing Medicare $143 million over 2 years”.

CMS has been working on a new process of paying for therapy based on resident characteristics rather than based on the amount of therapy provided.  It is anticipated that this new process with be similar to the hospital DRG process, with some sort of set payment amount for a particular condition. As a result of the study, the OIG is recommending that CMS accelerate its efforts to implement this new payment method and develop an interim process to accomplish two things:

1. Reducing the financial incentive to use assessments differently when increasing and decreasing the amount of therapy provided; and
2. Strengthening oversight of SNF billing changes in therapy

So, we will have to wait to see if CMS issues another layer of rules for the COT, EOT, and SOT assessments that are used for Medicare billing, or it they will instead accelerate the development of the new payment method for therapy services. 

 Contact:  Michelle Synakowski, msynakowski@leadingageny.org, 518-728-2365.