As part of the Affordable Care Act’s effort to make the healthcare system more transparent and informative for the public, the Centers for Medicare & Medicaid Services (CMS) have prepared a public data set with information on services provided to Medicare beneficiaries residing in skilled nursing facilities (SNFs). CMS Chief Data Officer Niall Brennan states that, “The Skilled Nursing Facility data released is yet another example of our commitment to greater data transparency.” The Skilled Nursing Facility Utilization and Payment Public Use File (SNF PUF) contains information on utilization, payment, submitted charges, Resource Utilization Group (RUG), and therapy minutes. The data in the SNF PUF contains information on 15,055 SNFs for calendar year 2013 and contains 100% final action (all claim adjustments have been resolved).
In addition to identifying almost $2.7 billion in Medicare payments for 2013, CMS used the SNF PUF data to run geographic comparisons of cost and utilization of SNF services. CMS found that the average Medicare standardized payment amount per stay for all SNFs was $10,919 with an average length of stay of 28 days. The states with the highest average standardized payment amounts included Indiana ($12,406); Texas ($12,064); and California ($11,862).
A considerable finding in the data contained information on the two highest RUG categories for patients who receive a significant amount of therapy: Ultra High (RU) and Very High (RV) rehabilitation RUGs. Based on the SNF PUF data, CMS found that more than one in five providers had more than 75 percent of both RU and RV assessments that showed therapy within 10 minutes of the minimum threshold. In California, Texas, Arizona, and Nevada, 70% or more of RU assessments were within the 10-minute threshold. Consistent with previous CMS findings, the SNF PUF data reinforces the allegations that many SNFs are inappropriately using RU and RV rehabilitation categories to increase their payments. As a result of this data analysis, CMS is providing approval to the Medicare Fee-for-Service Recovery Auditor Contractors (RACs) to investigate this issue. CMS wants to ensure that patient need is the primary driving factor for provision of therapy services rather than payment incentives. With the release of this new information and as always, SNFs should be monitoring therapy scheduling practices as well as providing detailed documentation to justify that services they provide and bill for are reasonable and necessary.