Cut into some apple pie instead of your MDS staffing budget
It was about an hour after the release of the Center for Medicare & Medicaid Services’ proposed rule for FY19, which contained the big Patient-Driven Payment Model reveal, that a wave of bold and somewhat uninformed statements surfaced.
It was equal only to the saturation of “PDPM experts” who have seized upon this opportunity. The volume of misinformation is notable. Is this our own version of “fake” news?
Here are some of my favorites:
- “The MDS is irrelevant in PDPM.” (Excuse me? I think I count only one non-MDS field.);
- “We have to make way for, and prepare for the ‘new resident’ coming in our buildings.” (… because up until PDPM they have been hiding precisely where?); and
- “I’m going to cut my MDS staff.” (Ouch!)
It’s the last I want to discuss.
Others and I have tackled many of these myths in various McKnight’s blogs, but I’ve yet to see a compelling analysis of the MDS volume issue, other than what was presented on page 387 of CMS’ final rule. That’s where the agency touts a cost savings of $195,925,878, or $12,664 per provider per year. I believe that is what’s behind some operators’ sentiment that it’s appropriate to make cuts to MDS departments.
I’m not sure how $12,664 translates into an MDS full-time equivalent in your building, but before we go there, consider the following:
- Who is taking on the responsibility of ICD-10 coding? It is a significant driver of PDPM reimbursement and MDS coordinators with additional education will be an important asset.
- CMS’s analysis didn’t consider ANY proxies for Interim Payment Assessments (IPA), as they had in prior analyses. No, IPAs are not mandatory at the moment, but, yes, you’ll still need to designate someone to complete them when appropriate.
- CMS’s calculations didn’t anticipate the growing Medicare Advantage population and associated requirements. Many Medicare Advantage plans require that you follow the PPS assessment schedule for its members.
- States often add additional data sets to the MDS to support their own needs. This is fluid, changing from year to year.
- The payment drivers for PDPM require greater clinical assessment skills and likely more time to complete.