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ATTN:PETER, RE: 5-Day Assessment

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HELLO ALL SNF/PPS AND CONUNDRUM LOVERS, CARE TO RESPOND TO MY ADDED

OBSERVATIONS BELOW??

>Thanks Anne Coffman and Dean Myers for your responses to the

>5-day assessment. I, too, am in agreement with your understanding

>of the regs. Nowhere does it state that a 5 day assessment is 5

>CONSECUTIVE days, and nowhere does it state that the assessment

>reference date MUST be day 1.

>

>>From the Federal Register: The first MDS assessment for Medicare eligible

>beneficiaries SHOULD (emphasis added) be completed by day 5 of the patient's

>SNF stay. The admission day counts as day 1. The Assessment Reference Date

>for the 5-day assessment MAY (emphasis added) be any day between days 1 and 5

>(although there is a 3-day grace period to day 8).

>

IT APPEARS THAT IF THE PATIENT IS ANTICIPATED TO BE DISCHARGED BEFORE DAY

11(THE EARLIEST ASSESSMENT DATE FOR THE " 14-DAY " THAT FOR ULTRA AND VERY

HIGH RUGS THE " 5-DAY " DATE SHOULD MAXIMIZE P MINUTES(BY USING DAY 7 OR 8),

IF THEY MAY STAY LONGER THAN 11 DAYS THEN THE " 14-DAY " WILL DETERMINE THE

PAYMENT FOR DAYS 15-45 AND SO THE P MINUTES SHOULD BE MAXIMIZED ON THE " 14

DAY " NOT THE " 5 DAY " (HENCE DAY 4 OR 5 WOULD BE BEST, 4+7=11).

WE ARE GOING TO USE DAY 7 FOR ALL PATIENTS TO AVOID EVEN FURTHER CONFUSION

FURTHER, SEE BELOW.------>

>

>>From some articles I have read, there are some very important details

>of the patient classification system that are not contained in the interim

>final rule published in the Federal Register (i.e., how patients can qualify

>for rehab groups based on expected therapies). Although the rule does say

>that facilities must record in Section T of the MDS all rehab therapy services

>that have been ordered and are scheduled to occur during the early days of the

>patient's SNF stay, nowhere does the rule specify the exact number of ordered

>therapy minutes needed to qualify for a particular RUG category. It is my

>understanding that HCFA intends to publish some kind of clarification

>regarding the RUGs classification system to minimize confusion from the

>Federal Register.

>

>For example, a patient is newly admitted, and ordered therapy (expected) and

>actual therapy minutes are recorded in Section T of the MDS.

Section P is filled out at admission?

You mean at day 1-8 section P and T are filled out(assessment reference date)?

>However, during>the first week, the minimum number of minutes for that

>RUGS >classification is>not delivered (7 days), but provided during the

>second week >8 days).

The second 8 days would be used as the actual minutes(P) for the " 14-day " .

the " 5-day " assessment determines payment for the first 14 days, the 14-day

for the next 30 days.

Question: e.g. " ultra high " category of RUGS one need have 720 minutes and

5 days of one discipline and 3 days of another. Is the 720 determined by

section P(actual minutes) or is it somehow averaged out with section

T(projected minutes). I don't understand which minutes will determine the

RUG sort(say for the " 5-day " ), currently it seems it is only P that matters

and so we are working to plan our care around getting the P minutes, but

then what is the function of T.

A previous response stated that " ultra " and " very high " will use P, and the

other RUGS level would use T, but how would the minutes then be calculated

for T, by some sort of averaging since the minutes that i've seen for these

other categories are by the week not by projections of 14 days ?

On the

>14-day assessment, Section P only looks back at the last 7 CONSECUTIVE days

>using day 14), and not the total 14 day period.

We were told that if the " 5-day " ARD is day 7, that our P minutes will go

back to the admission, but it sounds like for the P minutes on the

" 14-day " that the minutes would go from the ARD of the " 14-day " (day 11-18

allowable) only back 7 days?? OR is it from the ARD of the " 14-day " to the

ARD of the " 5 day " ???

Hence the facility will be

>paid for the RUGS classification assigned for the initial assessment period

>even though the minimum number of minutes was not achieved in the first week,

>and still, most likely, qualify for the same or higher RUGS classification on

>the 2nd assessment because the minimum number of minutes was delivered during

>the 2nd week. Somehow, I don't think this was HCFA's intention.

YES SO IF THE PATIENT IS A NON-ULTRA OR HIGH TYPE OF PATIENT, THEN ITS

BETTER IF THE ARD IS EARLIER BECAUSE SECTION T WILL DETERMINE THE AMOUNT

PAID, AND THEN THE ACTUAL MINUTES FOR P ON THE 14-DAY WILL BE HIGHER AND

THEY MIGHT GET INTO AN ULTRA/VERY HIGH ON THE " 14-DAY " , HMMMMMM.

THINKING OUT LOUD WITH YOUR PATIENCE,

M.

Ferdun, M.S., P.T.

paix@...

Maina, Guam, U.S.A.

" a rose is a rose is a rose by any other name "

______________________________________________________________________

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