FY 2014 Final Rule and MDS 3.0 Updates

FY2014 and More
HARMONY UNIVERSITY
The Provider Unit of
Harmony Healthcare International, Inc.
(HHI)
Presented by:
Keri Hart, MS CCC-SLP, RAC-CT, CHHRP-QT
Director of Rehabilitation & Reimbursement Education

Speaker Bio
Nearly 30 Years Experience in Long-term Care
Corporate Director of Clinical Reimbursement
Services
MDS
Corporate Rehab Director
Rehab Director
SLP
Cognition (Dementia and Head Injury)
Head and Neck (Dysphagia and Voice)
Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 2

“It is not the strongest of the
species that survives, nor
the most intelligent that
survives. It is the one that
is the most adaptable to
change.”
Charles Darwin

FY 2014 Final Rule:
Impact on Providers

Final Rule
On August 1, 2013, the Centers for
Medicare & Medicaid Services (CMS)
published the Final Rule for the
Prospective Payment System and
Consolidated Billing for Skilled
Nursing Facilities (SNF) for FY 2014
Effective October 1st, 2013 for FY 2014

New SNF Rates
The Final rule provides for a net market
basket increase for SNFs of 1.3% beginning
October 1, 2013
Full market basket increase of 2.3 percentage
points
Less a 0.5 percentage point multifactor
productivity adjustment required by Section
3401(b) of the Affordable Care Act (ACA)
Less 0.5 percentage point reduction to correct for
an error in forecasting the market basket in FY
2012

Impact on Providers
CMS estimates that the net market
basket update would increase Medicare
SNF payments by approximately $500
million in FY 2014
Nationally projected $7 per Medicare
patient day

Therapy Co-treatment
RAI User's Manual reporting
requirement for coding co-treatment
minutes on the MDS
Will not impact RUG calculation at this
time

Therapy Co-treatment
Indicator that CMS is concerned about
over utilization
Applies to Medicare Part A only
When two clinicians (therapists or
therapy assistants), each from a
different discipline, treat one resident at
the same time with different treatments,
both disciplines may code the treatment
session in full

Impact on Provider
MDS Software Update required
Rehab Software Update required
Rehabilitation Staff reporting required
on therapy logs
Rehab reporting to MDS
Ensure clearly defined

Distinct Days of Therapy
Add MDS Item 00420 (Calendar Days of Therapy)
Distinct calendar days of therapy
Clarify that classification criteria for the
Rehabilitation Medium RUG categories require that
the resident receive 5 distinct calendar days of
therapy
Clarify that classification criteria for the
Rehabilitation Low RUG categories require that the
resident receive 3 distinct calendar days of therapy
If not achieved the RUG would reduce to a Nursing
RUG
Applies to COT review and ARD Management

Current RUG classification allows
classification criteria for the Medium Rehab
category without 5 distinct days of therapy
Combination of 5 therapy visits
Current RUG classification allows
classification criteria for the Low Rehab
category without 3 distinct days of therapy
Combination of 3 Therapy visits plus 6 Days
restorative in 2 areas

Safety Net for missed therapy days
Potential Nursing RUG despite significant
therapy involvement
Only 4 Distinct Calendar Days:
PT 4 X 240
OT 4 X 240
ST 4 X 240
720

Distinct Days of Therapy-Daily Basis
The daily basis requirement can be met by
furnishing multiple therapy types on different days
of the week that collectively add up to "daily" skilled
services
CMS clarified that to meet this requirement the
patient must actually need skilled rehabilitation
services to be furnished on different days
"It is not sufficient for the scheduling of therapy
sessions to be arranged so that some therapy is
furnished each day, unless the patient's medical
needs indicate that daily therapy is required”

RAI Manual Updates
Released September 2013
Section O: Skilled Procedures
Reporting Co-Treatment Minutes
Section K: Nutrition
% Intake Artificial Route
While NOT a resident, While a Resident and
“During Entire 7 Days”

Impact on Provider
MDS Software Update required
Rehab Software Update required
Another factor in ARD Management
Increase in Change of Therapy (COTs)
Rate reduction retroactive 7 days
Increase Lower 14 Nursing RUGs
Increase audits and denials
Increase in use of Short Stay Policy
Providers still struggle with this
Potential for Rehabilitation Medium patients to not
meet Rehab skilled criteria

SNF Therapy Research Project
“Currently, the therapy payment rate
component of the SNF PPS is based
solely on the amount of therapy
provided to a patient during the 7-day
look-back period, regardless of the
specific patient characteristics”

“As an initial step, the project will review past
research studies and policy issues related to SNF PPS
therapy payment and options for improving or
replacing the current system of paying for SNF
therapy services received”
CMS has contracted with Acumen, LLC and the
Brookings Institution to identify alternatives to the
existing methodology used to pay for therapy
services received under the SNF PPS
CMS invites comments and ideas on the existing
methodology

CMS will “regularly” update the public on
the progress of this project on the project Web
site:
http://www.cms.gov/Medicare/Medicare-Fee-
forServicePayment/SNFPPS/therapyresearch.
html

Impact on Providers
SNF Therapy Research Project could
significantly change the reimbursement
model for therapy services provided
under Medicare Part A
Diagnosis may factor in

Presumption of Coverage
“The establishment of the SNF PPS did not change
Medicare’s fundamental requirements for SNF
coverage”
CMS proposes to continue presumption of coverage
for beneficiaries correctly assigned to one of the
upper 52 groups
Automatically classified as meeting the SNF level
of care definition up to and including the
assessment reference date on the 5-day assessment

Presumption of Coverage
“We note that this administrative
presumption policy does not supersede the
SNF’s responsibility to ensure that its
decisions relating to level of care are
appropriate and timely, including a review to
confirm that the services prompting the
beneficiary’s assignment to one of the upper
52 RUG–IV groups (which, in turn, serves to
trigger the administrative presumption) are
themselves medically necessary”

Impact on Providers
Warning by CMS to ensure
documentation of skilled coverage
criteria in the first days of a Patient’s
stay
Potential increase in audits

Consolidated Billing
Consolidated billing requirements are
unchanged
Acknowledged certain chemotherapy
items, chemotherapy administration
services, radioisotope services and
customized prosthetic representing recent
advances that might meet its criteria for
exclusion from SNF

Consolidated Billing
Corrections of error to the annual pricer
exclusion files will show that HCPCS codes
11042, 11043, and 11044 (surgical debridement
codes) will be corrected to ensure that they are
excluded from consolidated billing
“Flexibility to revise the list of excluded codes in
response to changes of major significance that
may occur over time (for example, the
development of new medical technologies or
other advances in the state of medical practice)’’
(65 FR 46791)

Consolidated Billing-Reminder
April 2013
The annual update file contains the
complete list of HCPCS codes that are
excluded from SNF CB for claims
submitted to Fiscal Intermediaries/A/B
MACS for payment
Effective for claims with dates of service
on or after 1/01/2013 unless otherwise
noted below

Swing Beds FYI
CMS notes that critical access hospitals
(CAHs) will continue to be paid on a
reasonable cost basis for SNF level
services furnished under a swing bed
agreement and that all non CAH swing
bed rural hospitals continue to be paid
under the SNF PPS

AIDS Add On
128 percent for SNF residents with Acquired Immune
Deficiency Syndrome (AIDS) remains
Transition from ICD-9-CM coding system to the ICD-
10-CM coding system starting October 1, 2014
ICD-10-CM diagnosis code of B20 for purposes of
defining AIDS Add-On. Includes AIDS, AIDS
related complex (ARC) and HIV infection,
symptomatic
Current code 042 also includes AIDS like
syndrome and new Final code B20 does not
Impact On Providers
May exclude some patients from meeting criteria

Physician Assistants-Certification
CMS finalized revisions to the regulation
related to the SNF level of care certification
and re-certifications by including Physician
Assistants in the provision authorizing nurse
practitioners and clinical nurse specialists to
sign SNF level of care certifications and re-
certifications
Impact On Providers
Allows additional Physician Extenders to sign
Physician Certification

CMS Review Impact FY2012 Changes
CMS concludes that it has found no evidence of
possible negative impacts that had been anticipated
by SNF providers in comments on the FY 2012 Final
Rule, particularly the potential for a “double hit” from
the combined impact of the recalibration of the FY 2011
SNF parity adjustment and the FY 2012 policy change
Recalibration of the FY 2011 SNF parity adjustment
to align with RUG-III
Allocation of group therapy
Implementation of changes to the MDS 3.0 patient
assessment instrument, most notably adding the
COT OMRA requirements

Distribution of MDS Assessments
MDS FY2011 % FY2012 %
Scheduled PPS 95 84
SOT 2 2
EOT 3 3
EOT/SOT Combined 0 0
EOT-R N/A 0
Combined SOT and
EOT-R
N/A 0
COT N/A 11

FY2014
Transition Memo released September
20th
Prior to RAI Manual Release

FY 2014 Transition
An MDS may generate a RUG that bills for
days in September 2013 (FY2013) and October
2013 (FY2013)
The CMS transition policy dictates payment
for these scenarios
In short, MDSs with an ARD from October 1st
through October 13th will generate a “FY2013
RUG” that will be communicated to billers
through the MDS validation report process

FY 2014 Transition
Facilities must ensure MDS/PPS
Coordinators communicate with the
Business Office to provide the MDS
transmission validation reports to
accurately bill
The FY2013 transition RUG will be
based on FY2013 RUG qualifications
and the FY2014 will require the new
requirements

Distinct Calendar Days of Therapy
MDS Change: For all assessments with
an ARD on or after 10/1/2013 must
include Item O0420 (Distinct Calendar
days) must be coded with the number
of distinct calendar days that the
resident received therapy services

RUG IV: Extensive Rehabilitation and
Rehabilitation Medium and Low Categories
Extensive Rehabilitation and Rehabilitation
Medium and Low Categories Criteria
Change: Rehabilitation Medium must have
greater than 5 Distinct Calendar Days and 150
Minutes of Therapy; Rehabilitation Low must
have 3 distinct calendar days and 45 minutes
of therapy with 2 rehabilitation/restorative
nursing for 6 days

COT reviews completed on or after
October 1st follow FY2014 requirements
of Distinct Calendar Days to meet
Rehab Medium and Low Criteria

Swallowing and Nutritional Status
Items
MDS Change: For all assessments with an
ARD on or after 10/1/2013 must include
K0710A and item K0710B with the proportion
of total calories the resident received through
parental or tube feeding and the average fluid
intake per day by IV or tube feeding,
respectively
RUG IV: Special Care High (fever) / Low and
Clinically Complex (ADL=0-1) K0710A and
item K0710B3 must be coded

FY2013 Transition RUG
September Days Billed October Days Billed
ARD on
or before
9/30/13
Bill actual RUG for all days of
service associated with that
assessment even if some of those
days of service are on or after
10/1/2013
Bill actual RUG for all days of
service associated with that
assessment even if some of those
days of service are on or after
10/1/2013
ARD
10/1/2013
through
10/13/2013
FY2013 transition RUG should be
used to bill any days of service
before 10/1/2013 which are
associated with that assessment
Bill actual RUG for FY2014 for
days on or after October 1st 2013
ARD date
after
10/13/2013
Not Applicable Bill actual RUG for FY2014 for
days on or after October 1st 2013

FY2013 RUG
An MDS with an ARD after 10/13/13
will not report a transitional RUG as
there is not a scenario when a MDS
with an ARD on or after 10/14/13 will
pay for days both in September and
October 2013

FY2014
Harmony Healthcare (HHI)
recommends implementing FY2014
RUG requirements for ARD planning
prior to the implementation date of
October 1st

Co treatment
Facilities are also reminded that effective
ARD 10/1/13, MDSs must also include of Co-
Treatment Minutes Item to MDS 3.0 (items
O0400A3A, O0400B3A, and O0400C3A)
Co-treatment must also be included in
individual minutes to calculate RUG
There is no change to the Rehabilitation RUG
categorization requirements for co-treatment;
therefore, there is no transitional RUG
required

PEPPER:
Program for Evaluating Payment
Patterns Electronic Report

PEPPER
This report will the SNFs detailed Medicare
claims data in certain targeted areas and
compare he SNF to other SNFs nationally
Skilled Nursing Facilities (SNFs) should have
received via mail on or about August 30, 2013
Envelope with red print on the outside
containing your facility specific PEPPER

PEPPER
PEPPER gives provider-specific Medicare
data statistics for services vulnerable to
improper payments
Allows providers to see how their facility
compares to all other SNFs across the state,
nation or Medicare Audit Contractors(MAC)
jurisdiction. PEPPER data is also shared with
both Medicare Audit Contractors (MACs) and
the Medicare Recovery Auditor Contractors
(RACs).

PEPPER
Targeted areas were derived from two
recent Office of Inspector General (OIG)
Reports:
“Inappropriate Payments to skilled
Nursing Facilities Cost Medicare than a
Billion Dollars in 2009” (November 2012)
“Questionable Billing by Skilled Nursing
Facilities” (December 2010)

Claims Data
The SNF PEPPER provides SNFs with their
jurisdiction, state and national percentile
values for each target area with reportable
data for the most recent three fiscal years
FY 2012 (October 1 2011 through
September 30th )is displayed on the first
table
When the target (numerator) count is less
than 11 for a target area for a time period,
statistics are not displayed

Target Areas
Therapy RUGs with High ADLs
Nontherapy RUGs with High ADLs
Change of Therapy Assessment
Ultra High RUGs
Therapy RUGs
90+ Day Episodes of Care

Episode of Care
Based on episodes of care
Defined as a series of claims for a patient where the
difference between the “Through Date” of one claim
and the “From Date” of the subsequent claim is less
than or equal to thirty days
Admission through Discharge
Considered same Episode of Care if readmission to
SNF (billed again) within 30 Days of discharge
Data includes episodes of care that end in period
reported

Therapy RUGs with High ADLs
Numerator : Count of days billed within
episodes of care ending in the report
period for Rehabilitation and
Rehabilitation Extensive RUGs
All Rehab “C” or “X” Days
Also includes RLB
Denominator : Count of days billed
within episodes of care ending in the
report period for all Rehabiliattion RUGs

Nontherapy RUGs with High ADLs
Numerator : Count of days billed
report period for Nursing RUGs
All Non Therapy “E”Days
Also includes BB1 and BB2 (Low ADL)
Denominator : Count of days billed
report period for all Nursing RUGs

Change of Therapy Assessment
Numerator: Count of assessments with AI
second digit equal to “D” within episodes
of care ending in the report period
“D” is a Change in Therapy Assessment
(COT)
Denominator: Count of all assessments
report period
COT initiated October 1st 2011 (FY2012)

Ultrahigh Therapy RUGs
Numerator: Count of days billed within
episodes of care ending in the report period
with RUG equal Rehabilitation Ultra High
or Ultra High Extensive
(RUC,RUB,RUA,RUX,RUL)
Denominator: count of days billed within
episodes of care ending in the report period
for all Rehabilitation RUGs
Not Total RUGs

Therapy RUGs
Numerator: Count of days billed within
episodes of care ending in the report
period for Rehabilitation RUGs
Denominator: Count of days billed
report period for all RUGs

90+ Day Episodes of Care
Numerator: Count of episodes of care
ending in the report period with a
length of stay of 90+ days
Denominator: Count of all episodes of
care ending in the report period

Compare Target Report
Page 1 (after introduction)
FY2012 only
When the SNF’s percent is at or above the national
80th percentile for a target area, the SNF’s percent is
printed in red bold
When the SNF’s percent is at or below the national
20th percentile for a target area the SNF percent is
printed in green italics
When the SNF is not an outlier, the SNF’s percent is
printed in black
Blank if Less than 11 SNFs in group

Target Count
Number of Episodes of Care
Shows Volume of Care
The “Target Count” can also be used to
help prioritize areas for review
Areas in which a provider is at/above the
80th percentile that have a large target
count may be given higher priority than
target areas for which a provider is
at/above the 80th percentile that have a
smaller target count

Percentiles
Percentiles are calculated for each of the three comparison
groups
State
Medicare Audit Contractor (MAC/FI) jurisdiction
Nation
SNF are to focus on National Data
Given the MAC may potentially use data for Additional Documentation
Requests (ADR) reviews, all data is important
SNFs whose target percents are at or above the 80th percentile
(i.e., in the top 20 percent) are considered at risk for improper
Medicare payments with areas at risk for overcoding
SNFs whose target percents are at or below the 20th percentile
(i.e., in the bottom 20 percent) are considered at risk for
improper Medicare payments with areas at risk for undercoding

Target Area Reports
Target area graph provides a visual representation of
the SNF’s target area percent over three years
Target Area SNF Data Table titled “Your SNF”
includes total number of episodes of care for the target
area (numerator) and total (denominator)
Roughly correlates to Patients Episodes
Based on the definition of the target area
Comparative Data for National, State and Jurisdiction
Some include 80th and 20th Percentile
Some only include 80th percentile
Average Length of Stay for the numerator and for the
denominator

Target Area Reports
CMS has developed “suggested
interventions” that SNFs may consider
when assessing their risk for improper
Medicare payments
These are “generalized suggestions and
will not apply to all situations”

Suggested Interventions
Therapy or Non-Therapy RUGs with
High ADLs greater than 80th Percentile
“This could indicate a risk of potential over
coding of beneficiaries’ activities of daily
living (ADL) status. The SNF should
determine whether the amount of
assistance beneficiaries need with ADLs as
reported on the MDS is supported and
consistent with medical record
documentation.”

Therapy or NonTherapy RUGs with
High ADLs less than 20th Percentile
“This could indicate a risk of potential
undercoding of beneficiaries’ADL status.
The SNF should determine whether the
amount of assistance beneficiaries need
with ADLs as reported on the MDS is
supported and consistent with medical
record documentation.”

Ultrahigh Therapy RUGs greater than
80th Percentile
“This could indicate that the SNF is
improperly billing for therapy services.
The SNF should determine whether
therapy provided was reasonable and
medically necessary, and that the amount
of therapy reported on the MDS is
supported by documentation in the
medical record.”

RUG Reports
SNF Top RUGs Report for all episodes of care lists
the top RUGs by number of days
SNF Top RUGs Reports episodes of care with 90+
days lists the top RUGs by number of days
Jurisdiction-wide Top RUGs Reports Report for all
episodes of care lists the top RUGs by number of
days
Jurisdiction-wide Top RUGs Reports episodes of
care with 90+ days lists the top RUGs by number of
days

RUG Reports
Each RUG Report Includes
Total episodes of care in the report period
RUG code and description
Number of RUG days billed
Percent of RUG days to total days
Percent of episodes of care with the RUG
billed total episodes of care
Average length of stay for the RUG

PEPPER
Impact on Providers:
Potential targeted audits in the areas listed
on the PEPPER
Opportunity to identify risk areas of over
utilization to ensure documentation supports
Opportunity to Identify areas of
underutilization that to ensure facility is
properly reimbursed for care provided and
ensuring patients have access to Medicare
benefits

Audit Environment:
More Changes

Increase in Medicare Documentation
Reviews
Significant increase in the number of medical review
requests from Medicare Administrative Contractors
(MACs)
Medicare Part A and B
Billing inconsistencies
ICD-9 Coding triggers
Similar pattern to Medical Record Reviews within
the nursing facility setting in the early 90's
Number of "Help Letters“ was astoundingly high
Investigations into potential fraudulent billing
practices increased

Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc. 70Copyright © 2012 All Rights Reserved Harmony Healthcare International, Inc. 70
Zone Program Integrity Contractor
(ZPIC)
Goal is to identify Fraud
CMS launched another major initiative
to target providers other than the
hospital setting as the RAC auditors
have been focusing on hospital audits
Southeast, South Central, Midwest,
Northeast and West Coast regions of
the U.S. are seeing the most ZPIC audits
at this time

Unified Program Integrity Contractor
(UPIC)
CMS is developing a new integrity contractor
called a Unified Program Integrity Contractor
(UPIC). The previous Medicare
Administrative Contractors (MACs) and
Zone Program Integrity Contractors (ZPICs)
will comprise the new contractor, though
MACs will not disappear entirely, they will
simply be absorbed by the UPIC. This
contractor will focus on both Medicare and
Medicaid integrity issues.

Medicare Recovery Auditors (RAs)
Recovery Audit Contractors (RACs) are
now known as The Medicare Recovery
Auditors (RAs)
The RAs post what area they are
targeting on the web. Providers are
able to review their jurisdiction’s
website for an update on what the RAs
are finding in their data collection.

Medicare Recovery Auditors (RAs)
RAs review claims on a post-payment basis
There are three types of review:
Automated (no medical record needed)
Semi-Automated (claims review using data and
potential human review of a medical record or
other documentation)
Complex (medical record required)
Look back up to three years from the date the claim
was paid
Required to employ nurses, therapists, certified
coders and a physician CMD

Be Prepared
Give Clinically Appropriate Care
Understand Medicare Coverage requirements
Technical
Clinical
Accurately document care provided
Bill accurately
Respond to documentation requests timely and
completely
Communicate trends and audit outcomes to staff
Get back to Basics !!

Medicare Part B:
Things are Getting Complicated

Overview of the Functional Reporting
Medicare Part B
Implemented Functional Reporting with a 6-
month testing period January 1 through June
30, 2013
Claims will be returned/rejected without
applicable G-codes and modifiers for dates of
services on or after July 1st 2013
G-Code FAQ released clarifying clinical
coding

Overview of the Functional
Reporting
Q6) Can therapists use any of the G-
Code sets or are they limited to those
corresponding to their discipline?
A6) The category G-Codes sets are not
discipline specific. The G-code set that
best describes the functional limitation
being treated should be used,
regardless of your discipline.

Reporting
Q10) When I begin reporting on my patient’s
second functional limitation, how do I report the
severity of its current status? Do I use the
severity modifier that reflected the current status
at the time of the initial evaluation or the one
from the time I began reporting?
A10) The severity modifier used to indicate the
beneficiary’s current status, reflects the severity
of the functional limitation at the time of the visit
for which Functional Reporting occurred

Reporting
Q12) How do I report the functional
information when I provide an evaluation
only and determine that the patient does
not need further therapy services?
A12) For one-time visits, you report all three
G-Codes for the functional limitation being
evaluated, along with the corresponding
severity modifiers for each

Reporting
Q14) How do I report an evaluative procedure when
it is for a different functional limitation than I am
currently reporting?
A14) You should report the evaluative procedure
furnished for a second/different functional limitation
other than the primary functional limitation for
which ongoing reporting is occurring as a one-time
visit (i.e., report all three (3) G-Codes in the code set
for the functional limitation that most closely
matches that for which the evaluative procedure was
furnished)

Reporting
A14 (Cont.)
The ongoing reporting of a primary
functional limitation is not affected by
the reporting of a one-time visit with s
all three (3) G-Codes in a code set are
reported for the secondary functional
limitation

Section 3005(g) of the Middle Class Tax Relief
and Jobs Creation Act (MCTRJCA) amended
Section 1833(g) of the Social Security Act to
require a claims-based data collection system
for outpatient therapy services
The system will collect clinical data on
beneficiaries function during the course of
therapy services in order to better understand
beneficiary conditions, outcomes, and
expenditures. This data will be used in
developing an improved payment system.

Implementation will not directly impact
reimbursement at this time
No actual payment for G Codes billed
Data collection process that likely will
be used at a later date to reform
Medicare Part B Therapy billing and
caps

Impact on Provider
Complicates Medicare Part B Billing
Complicates documentation
requirements for clinicians. Potential
denials if documentation requirements
to support G Code reporting are not
met
Increased Medicare Part B billing
rejections
Data may be used for audits

Manual Medical Review for
Medicare Part B-April 2013
Similar to the therapy cap, there is a
threshold of $3,700 for PT and SLP
services combined and another
threshold of $3,700 for OT services.
Such requests for exceptions will be
manually medically reviewed.
85Harmony Healthcare International, Inc.Copyright © 2013 All Rights Reserved

Manual Medicare Reviews for
April 2013: No longer required to submit
requests for exceptions to the threshold in
advance of furnishing therapy services above
the $3700
Recovery Auditors (RAC) will now conduct
prepayment review for all claims processed on or
after April 1, 2013. The specific process for
Manual Medical reviews is based on what state
services are provided.
86Harmony Healthcare International, Inc.Copyright © 2013 All Rights Reserved

Pre-Payment Review: Claims
submitted in the Recovery Audit
Prepayment Review Demonstration
states will be reviewed on a
prepayment basis
These states are Florida, California,
Michigan, Texas, New York, Louisiana,
Illinois, Pennsylvania, Ohio, North
Carolina, and Missouri

Post-payment Review: In the remaining
states, the Recovery Auditors will
conduct “immediate post-payment
review.” The MAC will flag the claims
that meet the criteria, request additional
documentation and pay the claim.

The MAC will send an ADR to the provider
requesting the additional documentation be
sent to the Recovery Auditor
The Recovery Auditor will conduct post
payment review and will notify the MAC of
the payment decision. The facility’s MAC will
then notify the therapy provider of the
outcome of the decision.

http://info.harmony-healthcare.com/symposium2013
Using the Promo code

Questions/Answers
Harmony Healthcare International
1 (800) 530 – 4413
Khart@harmony-healthcare.com
www.harmony-healthcare.com
Harmony Healthcare International, Inc. 9191Copyright © 2013 All Rights Reserved Harmony Healthcare International, Inc.

Harmony Healthcare International
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EVALUATION
or
CASE MIX ANALYSIS
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Email us at for more information
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Harmony Healthcare International, Inc.Copyright © 2013 All Rights Reserved 92Harmony Healthcare International, Inc.

FY 2014 Final Rule and MDS 3.0 Updates

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FY 2014 Final Rule and MDS 3.0 Updates