Hello, Patient Driven Payment Model.  It’s nice to meet you!

To an industry wondering if and when the RCS-1 System was coming, it looks like that question has been answered. Change is coming, but it’s going to look a bit different than we were expecting. On Friday, April 27th, CMS announced that the Patient-Driven Payment Model (PDPM) has been proposed to replace the RUG-IV System effective October 1, 2019.

It appears that many of the concepts of RCS-1 remain, primarily an end to a reimbursement system driven by therapy minutes.  PDPM includes what looks to be some very SNF-friendly improvements from an administrative / MDS standpoint.

While we anxiously await more information from CMS and more insight from industry experts, all indications are that reducing the near 140,000 payment combinations associated with RCS-1 was a priority.  The PDPM contains 80 % fewer combinations and appears, on the surface, to streamline the process considerably.

In terms of speech therapy, we will focus on the SLP Component.  The newly created SLP Component takes showcases the skill set of the speech therapist.  SLPs will have the opportunity to weigh in on the patient’s ability to eat, chew, and swallow, in addition to their cognition.

Among the other concerns with RCS-1 was very “loose” guidelines around delivery requirements for Physical and Occupational Therapy, and their controversial combination into one group.  Initial feedback suggests that PDPM has addressed this issue.

One more piece of exciting news is the inclusion of an $850 million-dollar payment increase for Fiscal Year 2019. Now it will be time to dig in, analyze the information, figure out how PDPM will affect operations, and put the systems in place for a smooth transition over the course of the 17 months.

CMS is collecting comments on its proposals until June 26 of 2018. In addition to the SNF PPS proposed rule, CMS also released updates to the prospective payment systems for inpatient psychiatric facilities, inpatient rehabilitation facilities, and wage index and payment rates for hospice.

We’d love to hear your thoughts!  Feel free to share below.