As 2017 closed, a number of projects kept me busy right up to the Christmas holiday. Among them was a focus on the SNF industry and its fortunes going forward, principally driven by clients in the investment industry. With REIT troubles, portfolio defaults on the part of HCR and Consulate, Sabra divesting Genesis facilities, and Genesis completely exiting Iowa, Missouri, Nebraska and Kansas—plus nervousness over rising debt levels and increasing operating expenses (before interest/debt and rent) at Ensign—there is growing concern about blood in the water and the arrival of the sharks, particularly for REITs, which hold a large number of the physical SNF assets. In May 2017, I wrote a post on Kindred, HCR, REITs, and where the SNF industry was headed. Today, it is time to reexamine the industry economically and structurally, looking at the policy and industry dynamics that will affect the fortunes of the SNFs and the firms that invest in them or the industry.
On January 1, 2017, two significant changes went into effect in the therapy world:
The Centers for Medicare & Medicaid Services (CMS) eliminated physical therapy (PT) and occupational therapy (OT) evaluation codes 97001 and 97003 and replaced them with three new tiered evaluation codes that contain descriptors based on the resident’s level of complexity (low, moderate, and high); and PT and OT reevaluation codes 97002 and 97004 were replaced with new CPT codes
Although these changes are over one-year-old, it’s important that clinicians take a step back in 2018 and revisit these new code sets to ensure they’re up to speed and coding correctly in the New Year. Keep in mind that these new codes should be used with all HIPAA-compliant payers, including Medicare Part A and Part B (to include RUGs currently, and RCS-1 if/when the industry transitions to that payment model), managed care, and private insurances/. This article will discuss the specifics of the new evaluation/reevaluation codes, when to use them, and billing implications of using the codes.
In the Office of Inspector General's (OIG) FY17 Work Plan, the agency outlined its plans for 2017, stating its intended focus on nursing home complaints and care area management, such as falls and abuse/neglect issues, as well as a continued dedication to investigating Medicare fraud and abuse. As we've seen through numerous media outlets and updates on the latest settlements, the OIG followed through with its intentions.