In its April 2016 Compendium of Unimplemented Recommendations, the OIG reminds CMS of the findings of its September 2015 report on the Medicare Payment System for SNFs. The key to that report is that OIG’s statement that SNFs billed for ultra-high therapy, which is the highest level, considerably more in the years reviewed even though the characteristics of the residents receiving the therapy did not show much change. It noted that this resulted in increased therapy billing to Medicare – a massive amount, in fact. The OIG found that $52 billion in costs could have been reduced if higher category RUGs had not been used, and then recommended that CMS figure out a way to evaluate how Medicare payment rates for therapy could be adjusted and change the rate of therapy payments.
CMS, according to the Compendium, is conducting a project to “study and evaluate” SNF therapy payment options.