Georgia State Office of Rural Health & HomeTown Health Best Practices for Compliance & Efficiency 2016-2017 Rural Swing Bed Management (RSBM) Training Program Use of Swing Beds in CAH Hospitals: SKILLED ANCILLARY SERVICES This project is supported by the Georgia Department of Community Health (DCH) State Office of Rural Health (SORH) grant number 16062G. Continuing Education Unit Conditions As an IACET Authorized Provider, HomeTown Health, LLC offers CEUs for its programs that qualify under the ANSI/IACET Standard. HomeTown Health, LLC is authorized by IACET to offer 0.1 CEUs/1 credit hour for this program today. In order to obtain these CEUs, you must: • View recording in its entirety within 30 days • Pass online quiz with 80% or better. • Complete webinar evaluation. RSBM Live Trainings for CAH RURAL SWING BEG MANAGEMENT: FOCUS ON COMPLIANCE North Georgia RSBM Program provided by HomeTown Health Habersham Medical Center, US Hwy 441 Business Demorest, GA August 25, 2017, from 9:00am to 3:00 pm South Georgia State Office of Rural Health, 502 Seventh Street South Cordele, GA August 18, 2017, from 9:00am to 3:00 pm 1
Agenda Welcome & Introduction Desi Barrett, Webinar Program Manager CAH Swing Bed Presentation: Kerry Dunning Skilled Ancillary Services RSMB Program Trainer Kerry Dunning, LLC Next Steps Desi Barrett, Webinar Dashboard & Calendar Program Manager RSBM Program Trainer Kerry Dunning LLC • Ms. Dunning has 20 years in health care consulting and over 30 years in the industry. • She specializes in the post-acute market working with hospital based skilled nursing and swing bed programs, critical access hospitals, freestanding skilled facilities, inpatient/outpatient rehab programs, inner city teaching hospitals and rural health care systems. • Ms. Dunning worked for HCA and HealthTrust hospitals in administrative roles; Horizon Rehabilitation and ServiceMaster Rehabilitation as a Sr. Vice President and Chief Operating Officer; with GPS Healthcare as the Chief Senior Services Officer; and has spent more than 20 years as an independent consultant. • In addition to serving as an Adjunct Instructor in the College of Health at the University of North Florida, Ms. Dunning regularly leads workshops and webinars regarding Medicare, skilled nursing (including MDS), swing bed programming, and reimbursement cycle improvement. She also works on international health care projects and research. • Her favorite job is on-site helping facilities take better care of patients. Kerry Dunning, MHA, MSH, CPAR, RAC-CT Kerry Dunning LLC CAH June 2017 2
Kerry Dunning has no proprietary interest in any product, instrument, device, service, or material discussed during this learning event. The education offered by Kerry Dunning, LLC in this program is compensated by the Georgia Department of Community Health (DCH) State Office of Rural Health (SORH) under grant number 16062G. Based upon Center for Medicare and Medicaid (CMS) Swing Bed Providers guidelines, Georgia State Office of Rural Health identified needs, and hospital based skilled nursing and swing bed program best practices, participants will be able to: 1. Recall CMS, OIG and MedPAC data regarding ancillary services usage 2. Recognize the required documentation to support ancillary services being provided 3. Understand the importance of physician documentation to support ancillary service usage 4. Comprehend SNF consolidated billing provisions set forth by Medicare for CAH hospitals. 5. Explain how to set up a self-audit of ancillary services, including tracking usage by physicians RCS – expected in 18 months 9 3
� Swing beds must follow skilled nursing guidelines but the rules are not always well defined. � CAH swing beds must be vigilant in understanding Medicare intent, documenting to CMS standards, and achieving measurable outcomes � Staff need to understand cost and how it is matched to medical necessity 10 SWING BED GUIDELINES Ancillary “defines” why USED TO BE THE ONLY GUIDELINES THE RULES HAVE CHANGED the complexity is such Enrolled in Medicare Part A Medicare Advantage follow Medicare intent that the service can only but insurance is a separate product be provided in a SWB Benefit days available to use Applies to Medicare and MC Advantage BUT 3-day qualifying acute inpatient admission Required by Medicare A; others vary from 1 to Ancillary cost “drives” 3; some headed for no qualifying hx stay the expenses that can cost more than the Qualifying condition The qualifiers have not changed f • • reimbursement Services must be provided for a Important that diagnoses documented condition which was treated during the during stay (including thx treatment qualifying acute inpatient admission; codes) are captured on the claim • or Still true for Medicare A but used less • Arose while the patient was in the because of reduced LOS swing bed for treatment of another condition for which the patient had been previously treated in a hospital Within 30 days of discharge Medicare A but insurance has to be pre-certed Requires daily skilled nursing services or All payors will consider Home Health or skilled rehabilitation which can only be Outpatient services as an alternative to the provided in a SNF or Swing Bed more expensive inpatient stay 11 � CMS ◦ Non-therapy services costs comprise about 25% of the daily costs of care for Medicare SNF residents ◦ An ALJ determined that Medicare paid for the hospital services under Part B as outpatient and ancillary charges and, therefore, Medicare would not cover the SNF services because the beneficiary did not have a three-day qualifying inpatient hospital stay. � OIG ◦ According to Medicare reimbursement rules, supplies and services that can be considered ancillary are limited to only those supplies and services that are directly identifiable to an individual patient, furnished at the direction of a physician because of special medical needs, and are either not reusable, represent a cost for each preparation, or are complex medical equipment. � MedPAC ◦ SNF Therapy Costs, and as a subset how other ancillary services are paid, and is the patient getting all services needed 12 4
� In 2011, Medicare spent nearly $32 billion on skilled nursing care* � Skilled nursing facilities offer: • Post-hospital and post-surgical care “SNF” regulations are the standard for • Assistance with activities of daily living any SWB program • Incontinence, catheter & colostomy care • Individualized care plans • Medication administration and IV services • Therapeutic and special diets • Diabetic management • Medical supplies and durable medical equipment during the stay • Restorative Rehabilitation services (SNF) • PT/OT/Speech-language pathology services • Pharmacy • Ambulance transportation * Source: Medicare Payment Advisory Commission 13 � Ancillary services fall into three broad categories: diagnostic, therapeutic and custodial. ◦ If your physician sends you for an x-ray of your injured leg, she is using a diagnostic ancillary service ◦ If after repairing the bone in your leg, she sends you to a physical therapist for proper exercise routines, she is using a therapeutic ancillary service ◦ Nursing homes providing custodial care are an ancillary service also � Non-therapy diagnostic tests and other typically Part B services are provided in the skilled setting 14 � CAHs have a 25 bed limit � CAH-based swing beds are cost-reimbursed � No MDS assessments are required � CAH SWBs are exempt from SNF PPS Consolidated Billing provisions BUT � The Atlanta Regional Office is now supplying at least one different interpretation of extraordinary cost and not consistent with the scope of services offered at the skilled level of care 15 5
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