On August 6, President Obama signed the Notice of Observation Treatment and Implication for Care Eligibility (NOTICE) Act (H.R. 876) into law, a move that many throughout the provider and patient camps have deemed an important, albeit preliminary step in reforming regulations that threaten residents’ access to vital long-term care and associated Medicare coverage.
GEM is a translation dictionary tool used to accurately and effectively translate or convert data from ICD-9 to ICD-10. This tool can be used by anyone who wants to convert coded data; however, it should not be used to code a claim, and is not a substitute for ICD-10 coding. GEM files are available at www.cms.gov/Medicare/Coding/ICD10/20. The GEMs are also known as crosswalks, as they provide important information linking codes of one system with codes in the other system.
The healthcare landscape is changing rapidly and frequently, compared to earlier periods. Providers generally had a substantial period of time to become accustomed to changes before they were required to be implemented. The proposed rule, released around May, would give us insight as to what the changes would be. Then providers would make their comments, with the final rule published by August and changes historically implemented October 1.
In its final SNF PPS rule for fiscal year (FY) 2016, released in late July, CMS pushed the bulk of its payment and practice reform–driven proposals from April through to fruition. In fact, one expert finds the two iterations of the rulemaking almost too close for comfort.
“It appears that CMS was rushing to get everything done, and they just did not change anything, which I think was surprising,” says David Gifford, MD, senior vice president of quality and regulatory affairs at the American Health Care Association (AHCA), a national trade association for long-term care providers. “We were generally disappointed that they didn’t take into consideration any of the comments. There were some really thoughtful comments … from a number of people.”
While experts doubt the final rule will blindside SNFs, they also warn providers against taking the forward-focused provisions—and their more distant implementation dates—too lightly. When coupled with the recently proposed overhauls to the industry’s long-untouched Conditions of Participation, the regulatory document bodes major changes to payment and care approaches for nursing homes in the years ahead.