As you may know, CMS announced that although the comment period for May's advanced notice of proposed rulemaking (ANPR) officially closed this August after receiving more than 200 comments, the agency encouraged providers to continue submitting feedback by sending comments, questions, or concerns to CMS. As a result, providers across the country are trying to determine what resources they should put into understanding this new payment model.
At Therapy Specialists, we are having frequent conversations about how RCS-1 might impact our business as well as the communities and facilities we serve. A few weeks ago, I spent some time with members of our clinical executive team talking about the unique aspects of RCS-1. Kelly Cooney, our VP of Compliance and Training, who is also a speech language pathologist, had some helpful thoughts on the role of speech therapy in RCS-1.
Here is an excerpt from our conversation:
Keith Carson: So, RCS-1 is proposing a single payment for providers based on clinical considerations in five areas — 1) PT and OT, 2) SLP, 3) Nursing, 4) Non-Therapy Ancillary and 5) Non-Case Mix. How will this affect us and then what are we doing now to prepare for this new model?
Kelly Cooney: I think for the speech piece, I know the National Speech Hearing and Language Association (ASHA), when I met with them recently, they were very excited about the fact that speech has a seat at the table and some significance in this new payment system that's being proposed. And I think as an organization we're uniquely poised to meet the needs because we have a robust speech program. We are staffed well in speech, unlike a lot of other therapy providers. And they haven't said yet whether, to get that extra money for speech, how much speech you actually need to provide.
Keith Carson: It could be just like checking a box?
Kelly Cooney: Right. You get it no matter how many minutes of speech therapy you provide the patient. We are hopeful that if they're going to pay for it that speech is something that is going to be an important part of that plan of care.
Kelly Cooney: And we're excited about that because I think speech has a real key role in some of the prevention of rehospitalizations, and getting people home sooner but safer. We work on identifying those executive function issues, especially in this time when resources are somewhat limited. Our rehab team might really need to focus on ADLs, to get the patient moving and get them home. Speech can pick up the cognitive, linguistic component and run with it. They can identify those issues that are going to lead toward re-hospitalization including swallowing, nutrition, and medication management. There's a lot of things that speech can do to help that patient and make sure that they get home safely.
Keith Carson: You talked about a robust program. Paint the picture for me. What is a robust speech therapy program?
Kelly Cooney: Sure. Well, in a lot of places when you ask about speech, all people think about is swallowing. The patient's coughing, therefore, I need to get a speech evaluation. That's a component of what we do, but it's not all we can do. We are working with patients with cognitive impairments, we're working with patients with speech and language problems, we’re working with patients with voice problems. We're catching those things on the short stay and putting them on a clinical treatment pathway to get them home.
Kelly Cooney: In conclusion, the structure of RCS-1 shows me that CMS has recognized that speech is a key player in improving the care and outcomes of the patients in skilled nursing facilities. At Therapy Specialists, we have recognized that already, and therefore, have staffed up and developed out our speech programs as a result. We believe the need for speech therapy services will only increase under this new proposed payment system.
You can learn more about what we believe rehab companies should be doing to prepare now for RCS-1 by viewing our blog entry titled "3 Things Your Rehab Provider Should be Doing Now to Prepare for a World Where Therapy Minutes No Longer Drive Your Reimbursement".