Draft Rules to Implement Bundling Posted

ODJFS recently put draft rules in “clearance” which include changes to the nursing facility chart of accounts and cost report necessary to implement the H.B.1 Consolidated Services provisions (bundling). It is important to note that these rules have not yet been filed as proposed rules.   There is a comment period through November 2, 2009. There could be substantial changes based upon the comments that ODJFS receives.

Bundled ancillaries that were previously billed directly to Medicaid are now reimbursed through the consolidated services add-on to the per diem rate. These include Oxygen, Therapies, Transportation, certain OTC Pharmacy and Custom Wheelchairs.  Since the cost incurred by the facility will now be reported on the annual cost report, the following changes to the chart of accounts and cost report were necessary. 
 

NEW ACCOUNTS

DIRECT CARE

6322.00	OXYGEN	(8/01/09 & Later  - Medicaid)
6323.00	OVER-THE-COUNTER PHARMACY PRODUCTS	(8/01/09 & Later - Medicaid)
6600.10	PHYSICAL THERAPIST SALARY	(8/01/09 & Later)
6600.20	PHYSICAL THERAPIST CONTRACT	(8/01/09 & Later)
6605.10	PHYSICAL THERAPY ASSISTANT SALARY	(8/01/09 & Later)
6605.20	PHYSICAL THERAPY ASSISTANT CONTRACT	(8/01/09 & Later)
6610.10	OCCUPATIONAL THERAPIST SALARY	(8/01/09 & Later)
6610.20	OCCUPATIONAL THERAPIST CONTRACT	(8/01/09 & Later)
6615.10	OCCUPATIONAL THERAPY ASSISTANT SALARY	(8/01/09 & Later)
6615.20	OCCUPATIONAL THERAPIST CONTRACT	(8/01/09 & Later)
6620.10	SPEECH THERAPIST SALARY	(8/01/09 & Later)
6620.20	SPEECH THERAPIST CONTRACT	(8/01/09 & Later)
6630.10	AUDIOLOGIST SALARY	(8/01/09 & Later)
6630.20	AUDIOLOGIST CONTRACT	(8/01/09 & Later)
6640.00	PAYROLL TAXES - THERAPY	(8/01/09 & Later)
6641.00	WORKERS' COMPENSATION - THERAPY	(8/01/09 & Later)
6642.00	EMPLOYEE FRINGE BENEFITS - THERAPY	(8/01/09 & Later)
6643.10	EAP ADMINISTRATOR THERAPY - SALARY	(8/01/09 & Later)
6643.20	EAP ADMINISTRATOR THERAPY - CONTRACT	(8/01/09 & Later)
6644.10	SELF FUNDED ADMIN. THERAPY - SALARY	(8/01/09 & Later)
6644.20	SELF FUNDED ADMIN. THERAPY - CONTRACT	(8/01/09 & Later)
6645.10	STAFF DEVELOPMENT THERAPY - SALARY	(8/01/09 & Later)
6645.20	STAFF DEVELOPMENT THERAPY - OTHER	(8/01/09 & Later)

ANCILLARY/SUPPORT

7631.00	RESIDENT TRANSPORTATION	(8/01-8/17, 10/01/09 FWD - Medicaid)
7735.00	CUSTOM WHEELCHAIRS	(8/01/09 & Later - Medicaid)

 

COST REPORT CHANGES:

• Schedule A-1 Summary of Inpatient Days:
  Column added to report Medicaid Managed Care days separately from “Veterans and Other.” Providers will have to track these days beginning January 1, 2009.
• Schedule B-2 Direct Care Costs:
  Adds lines for new Oxygen, OTC Pharmacy and Therapy accounts.
• Schedule C Ancillary/Support Costs:
  Adds lines for new Resident Transportation and Custom Wheelchairs accounts.
• Attachment 6 Wage and Hours Survey:
  Adds lines for new direct care therapy accounts. 
   

SUMMARY OF COSTS TO RECORD IN NEW ACCOUNTS:

We anticipate several changes to the proposed rules before final adoption. For example, all therapy costs are now included in direct care for all payor classes but there is no mechanism to offset the non-Medicaid portion. There is also no longer any place to put Medicare oxygen expense. We will be submitting detailed comments to ODJFS regarding these issues as well as others and will keep you posted as to any changes.

Excerpts from the draft rules are provided below detailing the costs to be recorded in each new bundling account:  

• "6322 Oxygen: Beginning 8/1/09 report all oxygen previously billed directly to Medicaid other than emergency stand-by in this account."
• "6323 OTC Pharmacy Products: Beginning 8/1/09 report all over-the-counter pharmacy previously billed directly to Medicaid in this account."
• "7631 Resident Transportation: For the period 8/1/09 - 8/17/09 and for 10/1/09 and forward report all resident transportation that was previously billed directly to Medicaid in this account. Resident transportation costs for the period 8/18/09 -9/30/09 are reimbursed on a direct bill basis."
• "7735 Custom Wheelchairs: Beginning 8/1/09 this account includes the cost of all wheelchairs and related repairs that were previously billed directly to Medicaid.”
• "Therapy Costs which are billable either to Medicare, directly to Medicaid by NFs, or other third-party payors. Report expenses through 7/31/09 in account numbers 9600 through 9700.2. Beginning 8/1/09 use account numbers 6600 through 6645.2 under Direct Care Therapies."