The Independent Regulatory Review Commission (IRRC) issued its comments to the Department of Human Services (DHS) this week in response to the proposed Patient-Driven Payment Model (PDPM) that DHS would like to adopt for Medicaid reimbursements.
IRRC’s comments mirror and validate the concerns PHCA has raised to both IRRC and state legislators. More than 80 percent of public comments on the PDPM proposal came from PHCA and PHCA members. Through these comments and subsequent meetings with IRRC, IRRC has pushed back on DHS “concur(ring) with the concerns raised by the Chairmen (Representative Doyle Heffley and Representative Perry Warren) and the public commentators.”
The change to a PDPM reimbursement model is a direct result of the Centers for Medicare and Medicaid Services (CMS) no longer recognizing the Resource Utilization Groups, Version III (RUG-III) classification system in setting Medical Assistance (MA) payment rates for nursing facilities. The purpose of this proposed rulemaking is to amend this data element in the DHS case-mix payment system for nonpublic and county nursing facilities.
DHS is proposing to use only the nursing care component of the PDPM in establishing a resident’s case-mix index score to be used in the case-mix rate-setting system. In other words, your nursing facility rate will not consider all the care provided to address resident needs and therefore not cover the costs for all the services you provide to your residents to maintain their well-being.
To read IRRC's comments, click here.
To read the proposed rulemaking, click here.
Author: Gail Weidman, director of policy and regulatory affairs with the Pennsylvania Health Care Association
