11th Oct

What rhymes with “PUF”? Bluff, cuff, gruff, rough, stuff, snuff, tough to name a few.

How does rhyming a word relate to therapy compliance? When you read the title, and read the word “PUF”, ‘puff’ is probably what came to mind. I didn’t’ spell it wrong. The word “PUF” is an acronym for Payment Use File.

The Centers for Medicare & Medicaid Services (CMS) provides information on services provided to Medicare residents in Skilled Nursing Facilities (SNF) through the Skilled Nursing Facility Utilization and Payment Public Use File (“PUF”). The information in this file reports on submitted charges, patient demographic, chronic condition indicators for each facility provider number, Resource Utilization Group (RUG), and the state where the SNF operates.

The PUF report containing 2015 data was just released and available on the CMS website. I know, 2017 is quickly ending and we are approaching 2018. So why is the data so old? The data contains 100% final action, which means, for example, that all claim adjustments have been resolved. Even though the data is almost 3 years old, there is valuable payment and utilization information contained within it about the services provided by SNFs. It doesn’t reflect the quality of care provided by each SNF nor is it risk adjusted in order to account for differences in the underlying severity of patient populations.

Of importance to SNFs and especially therapy providers is the Therapy Minutes Aggregate Table in the PUF report. This table contains information on the number of Rehab Very High (VH) and Rehab Ultra High (UH) assessments that were submitted by the SNF, as well as the percent of the VH and UH assessments where the total therapy minutes falls within 10 minutes of the minimum RUG level threshold. This is important because times are rough in the SNF world since we are under tremendous scrutiny. Government auditors will snuff us out as we try to work within the guidelines and the payment system developed by CMS. Perception of post-acute care providers is that we are trying to bluff the system when our only goal is to remove the stuff that is negatively impacting our residents and patients to improve their quality of life.

Do I sound gruff? Perhaps I am a bit frustrated by the PUF report. Where in the regulation does it say that we cannot deliver service during a look-back period totaling within 10 minutes of the minimum RUG threshold? RUG levels in the Prospective Payment System (PPS) have many regulatory specifications that need to be met and ensuring we aren’t delivering within 10 minutes of the minimum RUG threshold isn’t one of them.

What is a SNF and therapy provider to do? We are in a tough situation! However, there is peace of mind. That peace of mind is always doing what is right and clinically appropriate for our residents and then ensuring our documentation clearly paints the picture of the services we provided and the acuity of care delivered. Because at the end of the day, we all need to sleep at night. And avoid handcuffs!

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