Who doesn’t like a hug now and then? Giving and receiving a hug will decrease stress and show others that you care.

But when you “hug a RUG”, that will have the opposite effect. You will increase stress and the auditors will show you they care!

On March 9, 2016 CMS issued a report, which can be found by clicking on CMS fact sheet, outlining SNF Medicare payments through RUGs. CMS has instructed Medicare auditors to look at SNFs to determine if overbilling is taking place. The report states, “To help ensure that patient need rather than payment incentives are driving provision of therapy services, CMS is providing approval to the Medicare Fee-for-Service Recovery Auditor Contractors (RACs) to investigate this issue.”

So what’s the big deal? “Hugging the RUG” is the big deal because rather than each resident’s therapy care being individualized, the report shows industry patters of “hugging the RUG”. What does that mean? Take a look at the below information taken from CMS’ report:

CMS found that:

• 51% of all RV assessments showed therapy provided between 500 and 510 minutes.
• 65% of all RU assessments showed therapy provided between 720 and 730 minutes.
• For 88 providers, all of their RV assessments showed therapy provided between 500 and 510 minutes.
• For 215 providers, all of their RU assessments showed therapy provided between 720 and 730 minutes.
• More than one in five providers had more than 75% of both RU and RV assessments that showed therapy provided within 10 minutes of the minimum threshold.

Do you see the concern now? It clearly shows that the industry standard is to deliver therapy on or as close to the minimum amount of minutes necessary to meet the RUG—that is called “Hugging the RUG”. Since the delivered therapy minutes drive the RUG, which drives payment for the SNF, CMS clearly suspects that SNFs are overbilling. This has been a focus for years and the OIG report to Congress has addressed this concern.

And guess what? The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) has requested an increase of $77 Million for its FY 2017 budget to $419 million. The OIG cites several priority areas and one would wonder if this proposal to increase their budget will reflect an increase in government audits in the SNF…I would venture a guess and say, yes!

Therapy is under extreme scrutiny and it’s disappointing because SNF providers work hard to meet the needs of their residents. We aren’t overbilling! We historically have been poor documenters and because of this, we often times find ourselves being labeled as the people who “find loopholes” or who “overbill”. These stereotypes are ludicrous; residents come to us sicker and more acute and that is why we are providing so much care–because they need it, period.\

Gina Tomcsik, Director of Compliance | Functional Pathways