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The rehab industry continues to tell the Health Care Financing Administration (HCFA) what is wrong with the proposed prospective payment system (PPS) and why providers oppose certain changes. One of the biggest lightning rods has been the MDS-PAC, HCFA’s proposed new measurement tool.
"The MDS-PAC is onerous, and they haven’t field-tested it or verified that their data is reliable or valid," says Bonnie Breit, BS, MHSA, administrative director of rehabilitation services for Crozer Keystone Health System in Upland, PA.
Crozer Keystone sent HCFA its comments about the proposed PPS, including the observation that if the MDS-PAC is used then all of the rehab industry’s historical data from the widely used FIM system would be lost. This would mean that HCFA could not measure how rehab facilities are faring with regard to quality of care, length of stay, or even costs, between pre-PPS and post-PPS.
"It’s important to measure us with a tool where you can compare apples to apples," Breit says. "They should use a tool where you can check historically to see how you’re doing."
Although HCFA’s stated goal in proposing the MDS-PAC is that it will be a tool similar to what’s used in post-acute settings, the MDS-PAC clearly does not meet that objective because it’s different from the RUGS that nursing homes use and the OASIS tool used by home care agencies, Breit says.
The MDS-PAC is burdensome and time- consuming, says Bill Munley, MHSA, CRA, administrator of rehabilitation and the Vitality Center at Bon Secours St. Francis Health System in Greenville, SC.
Munley and Joe Golob, director of the St. Francis Inpatient Rehabilitation Center, have written HCFA a letter that outlines their concerns with the proposed rule and with the MDS-PAC.
"The majority (86%) of rehabilitation providers, ourselves included, use a smaller, much less burdensome instrument known as the functional independence measure (FIM)," they write. "It seems to make little sense to impose an essentially untested and untried, extensive, burdensome, and costly system that may cause harm to beneficiaries or providers at the outset of the IRF-PPS."
Another point made by the St. Francis administrators is that the basis for the MDS-PAC is the MDS 2.0 that is used in skilled nursing facilities, which have a much different philosophy than do inpatient rehab units.
The data HCFA are relying upon are flawed because they are old and geared toward a different patient population that likely will never become independent in the community, says Loretta McLaughlin, CPA, MBA, chief operating officer of Magee Rehabilitation Hospital in Philadelphia. "The resources I need for a 65-year-old, spinal cord injury patient who will go back into the community and live independently will be different from the 65-year-old person with a [spinal cord injury] who will be maintained in a nursing home," McLaughlin says.
The MDS-PAC assessment may take therapists up to 2.5 hours to complete, and facilities will have to make major modifications in medical record documentation in order to implement the new system, Munley and Golob write.
Concern about the time and cost burden of the MDS-PAC appears to be universal among inpatient rehab providers. "The MDS-PAC is a time-consuming tool that will need additional administrative resources," says Tom Smith, MBA, administrator of the Drucker Brain Injury Center at MossRehab in Philadelphia.
The Crozer Keystone comments to HCFA also point out that the MDS-PAC requires more frequent assessments than does the FIM tool. This also adds to the time and cost burden.
Golob and Munley urge HCFA, in their comment on the proposed PPS, to adopt the FIM system in place the MDS-PAC. "We also urge that the requirements for assessments other than admission and discharge be dropped," they write. "In doing so, HCFA can institute a payment system, as well as the desired quality monitoring system, and significantly reduce the burden and cost on IRFs."
• Peter Americo, MS, CCC, SP, Director of Rehab, Charleston Area Medical Center, 501 Morris St., Charleston, WV 25301-1326. Telephone: (304) 348-7626.
• Bonnie Breit, BS, MHSA, Administrative Director of Rehabilitation Services, Crozer Keystone Health System, One Medical Center Blvd., Upland, PA 19013. Telephone: (610) 447-2429.
• Sheldon Herring, PhD, Clinical Director of Traumatic Brain Injury Program, Roger C. Peace Rehabilitation Hospital, 651 South Main St., Greenville, SC 29601. Telephone: (864) 241-2600.
• Richard Linn, PhD, Director, Uniform Data System for Medical Rehabilitation and the Center for Functional Assessment Research, 232 Parker Hall, Suny & Buffalo, 3435 Main St., Buffalo, NY 14214. Telephone: (716) 829-2076, ext. 34.
• Loretta McLaughlin, CPA, MBA, Chief Operating Officer, Magee Rehabilitation Hospital, Six Franklin Plaza, Philadelphia, PA 19102. Telephone: (215) 587-3200.
• Bill Munley, MHSA, CRA, Administrator of Rehabilitation and the Vitality Center, Bon Secours St. Francis Health System, One St. Francis Drive, Greenville, SC 29601. Telephone: (864) 255-1871.
• Charles Schuessler, Chief Financial Officer, The Children’s Institute, 6301 Northumberland St., Pittsburgh, PA 15217. Telephone: (412) 420-2203.
• Tom Smith, MBA, Administrator of Drucker Brain Injury Center, MossRehab, 1200 West Tabor Road, Philadelphia, PA 19141. Telephone: (215) 456-9472.