Medicare Proposes SNF Rule Changes ASHA Comments on Group Treatment, Student Supervision in Nursing Facilities Policy Analysis
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Policy Analysis  |   August 01, 2011
Medicare Proposes SNF Rule Changes
Author Notes
  • Mark Kander, director of health care regulatory analysis, can be reached at mkander@asha.org.
    Mark Kander, director of health care regulatory analysis, can be reached at mkander@asha.org.×
Article Information
Regulatory, Legislative & Advocacy / Policy Analysis
Policy Analysis   |   August 01, 2011
Medicare Proposes SNF Rule Changes
The ASHA Leader, August 2011, Vol. 16, 3. doi:10.1044/leader.PA2.16082011.3
The ASHA Leader, August 2011, Vol. 16, 3. doi:10.1044/leader.PA2.16082011.3
ASHA has prepared comments in response to two proposed Medicare regulations related to speech-language treatment provided to Medicare Part A patients in skilled nursing facilities (SNFs). The proposed regulations, which become effective Oct. 1, restrict group treatment and remove restrictions on supervision of students.
Group Treatment
Under current Medicare regulations, “group treatment” may include two to four patients. The Centers for Medicare and Medicaid Services (CMS) proposes to restrict group size to four. If fewer than four patients participate, providers would be allowed to credit only one-fourth of the treatment minutes to each patient. A clinician providing a 30-minute group treatment, for example, would credit each patient (for reimbursement purposes) with seven minutes of treatment (30 minutes ÷ 4), regardless of the number of patients in the group.
CMS states that with two or three participants, “the opportunities for patients in the group to interact and learn from each other are significantly diminished given the small size of the group.” CMS cites no evidence to support this claim. ASHA asserts that smaller groups are reasonable.
The proposed division of group minutes also reflects a change. Under current regulations, a 30-minute group treatment session counts as 30 treatment minutes for each patient (a total of 120 minutes for a four-member group). The proposal, however, would allocate the treatment minutes among participants (30 minutes total, seven minutes per patient). CMS has stated that recording 30 minutes of provider time as 120 minutes for four patients constitutes inaccurate recording of resource allocation.
Student Supervision
The current requirement for supervision of speech-language pathology students is “line-of-sight” by a supervisor who may not be treating other patients simultaneously. In its proposal, CMS states that other Medicare Part A inpatient settings (e.g., hospitals) have no such restrictions and “we consider it inequitable for SNFs to be subject to a more restrictive set of standards in this regard.” Therefore, “each SNF would determine for itself the appropriate manner of supervision of therapy students consistent with applicable state and local laws and practice standards.”
In its comments, ASHA submitted recommendations that would prevent the overuse of students by SNF administrators.
The full text of the proposed regulations is online at the Federal Register [PDF]. The comment letter is on ASHA’s website [PDF].
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FROM THIS ISSUE
August 2011
Volume 16, Issue 8