Tell CMS Nutrition Care Matters

The Centers for Medicare & Medicaid Services (CMS) is considering removing malnutrition and tube feeding from reimbursed care in under the Patient Driven Payment Model (PDPM).

One of the greatest perils our elders face is maintaining nutritional health. Peer-reviewed research has shown time and time again that without adequate nutrition individuals do not recover from illness, experience falls, functional decline, or are re-hospitalized.

At DiningRD, we know that treating malnutrition comes at a great cost to our communities. It is only fair and right to support this valuable work with resources and reimbursement from CMS to prevent and address malnutrition, risk for malnutrition, and tube feeding for our residents!

YOU CAN HELP! Tell CMS that nutrition care matters.

Submit your comments here

Here is a sample letter you can use to add/edit/revise and submit to CMS:

Dear Administrator,

[Add information about your self- ex: I am a Registered Dietitian Nutritionist with 10 years of experience assessing and treating malnutrition in a SNF. Thank CMS for the opportunity to comment and collaborate].

Registered Dietitian Nutritionists (RDNs) play a critical role in addressing malnutrition and developing tailored nutrition care plans. Interdisciplinary collaboration, including RDNs, is essential in providing holistic care for residents in long-term care facilities.

I am writing to highlight the critical importance of continuing to recognize malnutrition and at-risk status for malnutrition in the Conditions and Extensive Services Used for NTA Classification List. Malnutrition is a prevalent health issue among the Medicare population, particularly affecting older adults with multiple chronic conditions and those who are food insecure.

The clinical and economic impacts of malnutrition cannot be understated. Studies have shown that malnutrition leads to higher healthcare utilization, increased mortality rates, longer hospital stays, and greater healthcare costs. The economic burden of disease-associated malnutrition alone is estimated at $157 billion in the United States, with a substantial portion attributed to individuals aged 65 and older.

Given the widespread prevalence and considerable financial implications associated with malnutrition, it is imperative for CMS to uphold the provision of payment models and incentives that facilitate comprehensive screening and diagnosis protocols and promote interoperability to ensure timely and accurate identification and treatment of patients affected by malnutrition or at risk thereof.

It is important that CMS provide clear guidance and specific coding criteria for malnutrition or at-risk-for-malnutrition within the Long-Term Care Facility Resident Assessment Instrument (RAI) manual. There is currently a lack of specific examples or coding criteria for malnutrition or at-risk-for-malnutrition, such as those provided for other items like UTI.

This absence of standardized coding criteria can lead to variability in coding interpretations and may result in confusion among healthcare providers. By offering clear guidance and specific criteria for coding malnutrition or at-risk-for-malnutrition, CMS can ensure consistency and accuracy in coding practices across healthcare facilities. This will facilitate accurate assessment and documentation, support appropriate care planning and resource allocation, and enable better data collection and analysis for quality improvement initiatives.

Continuity of care during transitions between care settings is also crucial for addressing malnutrition effectively. RDNs play a key role in assessing nutritional status, developing personalized treatment plans, and ensuring seamless care transitions for patients at risk of malnutrition.

Prompt identification and treatment of malnutrition are essential to prevent adverse outcomes during transitions between care settings.

Addressing malnutrition is vital for health equity and access to quality healthcare. Incentivizing the screening and treatment of malnutrition promotes equitable access to nutrition care and supports vulnerable populations, such as older adults from minority and rural communities.

Thank you for your consideration.
Sincerely, [Your Name]

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