Therapy:
BRACE FOR THERAPY SCRUTINY UNDER PPS CHANGES
Published on Mon Aug 20, 2007
Will 6, 14 visits become the new 10?
Get ready for a complete overhaul of how therapy affects your PPS payments.
Under the finalized prospective payment system refinements, home health agencies will see a change from the current 10-visit threshold for therapy to a three-tired threshold at 6, 14 and 20 visits. The system will include so-called “smoothing” payments in be-tween those levels.
The three therapy tiers included in the Aug. 22 final rule are the same as those proposed back in April, notes therapist Cindy Krafft, consultant with Fazzi Associates in Northampton, MA.
But payment for the different case mix levels for therapy vary slightly from the proposed rule, adds consultant Mark Sharp with BKD in Springfield, MO.
The Centers for Medicare & Medicaid Services doesn’t spell out what the pay differences are for the numbers of therapy visits. But you can deduce that information from Tables 4 and 5 in the final rule, Sharp tells Eli.
First you have to know whether the patient is in an early (first or second) episode or a later (third or later) one. Then you can look up which “Service” level the episode falls into based on number of therapy visits. CMS cut the OASIS item on prior inpatient stays, M0175, from case mix consideration, so therapy is now the only item that determines the “S” level in the CxFxSx home health resource group, Sharp explains.
Example: An early episode with six visits is an S2 level, according to the therapy level chart on p. 49825 of the final rule in the Aug. 29 Federal Register. You can then look up S2 in Table 4 on p. 49826 and see that it adds $608.54 to the PPS base rate for the episode. Be sure to look in the 1st and 2nd episode category, not the later episode category.
With the base rate at $1,322.84 for early episodes, the added therapy payment for S2 brings that total to $1,931.39 for C1F1S2, according to Table 5 on p. 49828 of the FR final rule. If the Clinical and Functional domains go up, the total episode payment still increases by $608.54 for the six therapy visits, Sharp says.
Payment increases for therapy get smaller as the number of therapy visits goes up, Krafft says. “There is a deceleration in the payment in order to decrease the incentive to just do more visits,” she points out.
Gaming risk: But the industry is still going to face some pretty compelling incentives to furnish more therapy visits, Sharp expects. [...]
