Parity means the state of being equal. We all want to be in a state of equality, right? Supporting parity is important in many aspects of our lives and recently in the Skilled Nursing Facility (SNF) Fiscal Year (FY) Proposed Rule for 2022, The Centers for Medicare and Medicaid Services (CMS) talks about the Patient Driven Payment Model (PDPM) and recalibration of the PDPM parity adjustment. 

I believe that we are all in agreement that PDPM was intended to be budget neutral when transitioning from RUG-IV to PDPM. We did not have any tricks up our sleeves to find a “loophole” to increase payments. Our patient characteristics speak for themselves. What we did as providers is train our front-line care staff on documentation improvements to ensure proper accounting of all the care provided to residents. We invested in our care staff by diligently working hard to provide more advanced training, not only with documentation, but on breaking down to the granular levels of our mediocre documentation and coding practices. Simply put, we did a better job obtaining patient records from the hospital and documenting the acuity of care details in our documentation, which led to better coding on the Minimum Data Set (MDS). It is simply that simple! We got better because we had to.

For the better part of twenty years, the therapy industry has been scrutinized. Our documentation practices in Post-Acute Care (PAC) needed improvement and, in many cases, still do. My mentor once told me, “It’s not a matter of IF you are going to receive a government audit, it’s a matter of WHEN!” And she was right. Think about all of the entities waiting to audit our records: Medicare Administrative Contractor (MAC) audits, Target Probe Educate (TPE) audits, Recovery Audit Contractors (RAC) audits, Comprehensive Error Rate Testing (CERT) audits, and the list goes on and on and on. Rightfully so, in my opinion since there are so many wrongdoers out there trying to scam their way to wealth. Those wrongdoers should be caught, and justice served. But for us little guys out there, trying to survive the storm, we just want to be recognized for the amazing work we do in the PAC Setting, specifically in the SNF. We make a difference in the lives we touch every single day. We not only provide necessary medical care, but we also provide companionship, friendship, understanding, compassion, love, joy, peace, kindness, and goodness to our most vulnerable.

The COVID-19 PHE taught us a lot of lessons, one being how essential therapy and SNFs are in the lives of those we care for. We understand that the data shows there is an increase in SNF spending in the very beginning months of PDPM implementation before COVID hit. Think about where the increases are, Speech Language Pathology Component, Nursing Component, and the NTA Component….in my opinion, PDPM worked as it should by categorizing patients based off their clinical characteristics. It worked as intended! But seriously, is that really enough time for data collection and analyses to be made? Removing patients with a COVID-19 diagnosis and patients under the 3-day hospital stay requirement waiver, the data shows a 5% increase in spending under PDPM.  Did anyone consider when the COVID-19 diagnosis was actually communicated to providers to use? What about those patients who actually had COVID-19 and were not diagnosed, but yet had symptoms and required treatment? For those sitting in an office pulling data, removing COVID-19 patients from the data pull, is not reality. There was so much going on that a lot of patients may not have even had the COVID-19 diagnosis because it was not available to providers in the beginning.  Did anyone consider this thought? 

Fact is, we are still under a PHE. There are variants of the virus hitting those who are not vaccinated. Now is not the time to consider recalibration of the PDPM parity adjustment on such little available data and while our wounds are still bleeding.

Gina Elkins, Senior Director of Compliance and Regulatory Strategy