The Skilled Nursing Facility industry has been preparing for Resident Classification System (RCS-1) since last Spring, when the Advanced Notice of Proposed Rule making outlined a new Medicare Part A reimbursement system to replace the existing RUG IV system. Stakeholders from Washington DC, who felt the RUG system had disproportionate incentives for SNFs to provide excessive therapy minutes to enhance reimbursement, have been advocating for a replacement to the RUG system for some time.

RCS-1 appeared to be the answer to their prayers. By creating a system focused on the clinical condition of the resident, the industry would move away from a system heavily based on resources utilized (first two words in RUG), specifically minutes of therapy.During the Skilled Nursing Facility (SNF)/Long Term Care (LTC), Open Door Forum held on Thursday, March 8, John Kane, the skilled nursing team lead for CMS, said the agency continues to review and analyze the “significant number of comments” received by his office.  Therefore, CMS has not established a timeline for the implementation of RCS-1.  Maybe the near 140,000 potential RCS-1 rate outcomes were a little much?

In speaking with attendees at the recent 49th Annual New York Chapter of the American College of Health Care Administrators, they are currently facing a multitude of challenges including staffing shortages, improving Five-Star ratings and a new survey process.  Preparing for payment reform has also been near the top of that list. So, can we expect to see RCS-1 in the FY 2019 SNF Proposed Rule next month? Suddenly, that seems like a longshot. Will RCS-1 be squashed in its entirety on our way to the Unified Post-Acute Payment System being planned by MedPAC for a 2021 implementation? That is a definite possibility. Or perhaps RCS-1 will still happen at a date later than October 1, 2018?  Don’t be surprised at that one either. Many industry stakeholders (including the Speech Therapy profession 😊) have been excited RCS-1.

For now, we shall all wait and see….. Questions about RCS-1, Speech Therapy Operations, Rehab or perhaps something else?  We’d love to help.  Please feel free to share your thoughts in the space below.