A Proposed Rule by the Centers for Medicare & Medicaid Services on 05/08/2018Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities (SNF) Proposed Rule for FY 2019, SNF Value-Based Purchasing Program, and SNF Quality Reporting ProgramCMS is recommending changes to the reimbursement system for SNFs by replacing the Resource Utilization Grouping matrix (RUGs). The proposal is posted on the link above and the comment period is only open until 6/26/18. The new proposed grouper places more emphasis on accurate and complete ICD-10 coding which would also include ICD-10 procedural coding, which we have never done in the LTC setting. The proposal also assumes that we receive pertinent and timely information from the hospital in order to render the codes on the MDS. The concern is that most LTCFs do not employ appropriately trained coders to accurately perform this vital function which in the proposed rule, will impact certain reimbursement categories.An independent group of like-minded-HIM peers have gotten together and drafted a letter with our comments and recommendations to CMS. (Hopefully I will be able to attach it to this post successfully!) . If you also feel compelled to add your voice to our concerns, please feel free to use this letter and add your name, or modify or change it to your own liking if you wish, and please send to CMS by the deadline of 6/26/18.NOTE: THIS LETTER IS NOT AN AHIMA VETTED, NOR AHIMA ENDORSED LETTER. It is simply an action by a concerned group of professionals who work in the SNF arena and are very concerned about the impact of this proposed ruling.