On April 25, 2019, the Centers for Medicare & Medicaid Services (CMS) published a notice of proposed rulemaking that would revise the definition of group physical, speech and occupational therapy to allow six residents, rather than four, to participate in a group therapy session. If finalized, the rule would place even more nursing home residents at risk of receiving less individualized therapy. The Center for Medicare Advocacy (The Center) and the Long Term Care Community Coalition (LTCCC) have written comments detailing our concerns:
- Under the Patient Driven Payment Model (PDPM), which will be
implemented in October 2019, Medicare reimbursement will be based on
patient characteristics and not therapy minutes. As a result, nursing
homes will have a financial incentive to provide the least costly mode of
therapy possible to residents, rather than the highest quality for each
individual.
- While only 25 percent of a resident’s therapy regimen, by
discipline, can be provided in group or concurrent therapy, CMS makes clear that there “will be no
penalty for exceeding the 25% combined . . . therapy limit.” This failure
to properly enforce the group therapy limit means that nursing homes will
not be held accountable for putting financial incentives over resident
care.
- By revising the definition of group therapy to allow more
residents to participate in one group therapy session, CMS will make it
easier for nursing homes to forgo individual therapy for even more
residents at one time and without meaningful accountability.
To access our comments, please visit https://www.medicareadvocacy.org/cma-comments-on-snf-payment-quality-for-fy-2020/.
If your organization would like to sign-on to our comments, please contact Dara Valanejad, Policy Attorney (Center & LTCCC), at dvalanejad@medicareadvocacy.org or 202-293-5760.
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