12 steps to MDS, RUGS preparedness
Watch what happens at the SNFs
Unless officials at the Health Care Financing Administration make a 180-degree turn, your facility will rate patients with the Minimum Data Set (MDS) and receive per diem payments based on the Resource Utilization Groups System (RUGS) in October 2000.
The MDS and RUGS, which go into effect as a prospective payment system (PPS) for skilled nursing facilities (SNFs) July 1, 1998, will be a challenge for rehab providers because they are like no other measuring tool currently used in the rehabilitation field.
It’s not too soon for rehab providers to begin looking at the changes they should make to adapt to the MDS, warns Doris Reinhart, principal of Chesapeake Consulting Inc., an Alexandria, VA, health care consulting firm specializing in post-acute providers.
The rehab field has an opportunity to observe what happens when SNFs go live with their PPS in July and to learn from them, Reinhart says. She offers these 12 tips to help your facility prepare:
1. Take advantage of being in a cost-based environment for the next 21¼2 years. If you need to make capital improvements, update your computer system, or hire a consultant, do so now while you still will be reimbursed for it. The new reimbursement system will roll routine, ancillary, and capital costs into a per diem rate.
2. Consider increasing staff now while you are under cost-based reimbursement. The MDS in its present form is complicated. Facilities in the SNF demonstration project found they needed additional staff to handle it. It’s important that the staff be thoroughly trained in the MDS so patients can be assessed properly and put into the appropriate categories.
3. Start educating your staff now about the PPS and the switch to MDS. It will affect every aspect of your operation. Organize activities that show the effect of a PPS on your organization.
4. Start to get familiar with the MDS and RUGS. You can get a copy of them, along with explanatory documents, on the Internet at: http://www. alliedtech.com/research/health.html.
5. When the revised version of the MDS for rehab is published, establish a baseline for your facility, based on historical data. Look at how you would have fared in the past. Determine which patient groups you might have lost money on and consider making program changes to lower the costs.
6. Start documenting current patients on the MDS long before October 2000. At some point, you will need to use your current documentation method (probably the Functional Independence Measure) and the MDS for all patients.
"It’s more work. You’ll have to run dual systems, but when you go live, nothing will be new," Reinhart explains.
Some of her SNF clients have tried the MDS gradually, documenting every third patient at first. Others have jumped into it and documented all patients at once to see what effect it has on their facilities.
"What is important is that you and your staff are thoroughly familiar with the MDS when the PPS system goes into effect," Reinhart explains.
7. Focus on the functional needs for discharge. Set discharge goals based on what the patient needs for discharge, not what you would like to do or are capable of doing. "You need to help your staff develop a continuum-of-care point of view, to get used to the idea that yours is not the only setting," Reinhart says.
8. Consider co-treatments as part of your cost-saving structure. RUGS prescribes a minimum number of minutes of treatment per week for patients in each category. This will make group therapy far more cost-effective than individual treatment, Reinhart says. Under HCFA rules for SNFs, groups are limited to four patients per staff person who must be a therapist or a licensed assistant. "Don’t do away with one-on-one but find the combination that makes sense," she adds.
9. Make sure you deliver only as much therapy as a patient needs. Carefully document the time you spend with patients and monitor it carefully to stay within the category for which you will be reimbursed. For instance, the "very high" rehab category in RUGS specifies a minimum of 500 minutes a week. If you give 530 minutes, you won’t get paid for the last half hour.
10. Consider dovetailing treatments for higher-level patients. This means a physical therapist can set up one patient on a machine for treatment, then set up a second patient and monitor both.
11. Make greater use of therapy extenders, such as physical therapy assistants and certified occupational therapy assistants. "The minutes are on a per-patient basis and include all minutes of therapy. When you look at the costs, using extenders and groups will give you a lower overall cost," Reinhart says.
12. Consider team evaluations. Evaluation time does not count toward the minimum treatment time for each category of patients. This makes it necessary to make the most of your evaluation time, because it is a cost.
"For every discipline to do its own evaluation is costly. You should examine ways to cut down on this," Reinhart says.
[Editor’s note: Doris Reinhart may be reached at (703) 212-0040.]
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