Switching from RUG to the Nursing PDPM Component: What Skilled Nursing Facilities Need to Know 

by Mary-Beth Newell, SVP Clinical Reimbursement, Limitlessli

 

As more states transition their Medicaid case mix reimbursement models from the RUG (Resource Utilization Group) system to the nursing component of PDPM (Patient-Driven Payment Model), skilled nursing facilities are facing new challenges—and new opportunities. While the removal of the Rehab category may seem like a loss at first, this shift offers a more clinically aligned and financially fair approach to resident classification.

Here’s what SNFs need to know to prepare for and benefit from this transition. 

Understanding the Shift: From RUG to PDPM Nursing Categories 

Transitioning to the nursing PDPM component means eliminating several conditions from reimbursement calculations under the old RUG system. These include:
 

  • Rehab category 
  • Suctioning 
  • Aphasia with tube feeding 
  • Dehydration 
  • Days of physician visits or orders 
  • Internal bleeding 

What’s New in the PDPM Nursing Component 

Extensive Services: Narrower, Sharper 
The PDPM Extensive Services category now includes: 

  • Isolation (new addition) 
  • Tracheostomy care 
  • Ventilator use 


IV fluids now group to Special Care High, and IV medications fall under Clinically Complex instead of Extensive Services.
 


Special Care Gets Split: High vs. Low
 
PDPM introduces Special Care High and Special Care Low, offering more nuanced categorization.

Special Care High now includes:
 

  • Comatose and dependent residents 
  • Residents requiring insulin with two or more insulin order changes 
  • Sepsis/septicemia 
  • Residents with depression (PHQ-9 score of 10+) 


Special Care Low now includes:
 

  • Parkinson’s disease with a nursing function score ≤11 
  • Respiratory failure with oxygen use 
  • Dialysis 
  • Tube feeding (≥26% calories and ≥501 cc fluids/day) 
  • Foot infections with treatment 


Behavioral and Cognitive Changes
 
The PDPM model merges Impaired Cognition and Behavior Only into a single category with fewer levels. Restorative nursing still functions as a case mix split here. 

How Facilities Can Prepare for a Smooth Transition 

Track Isolation Early 
Isolation now qualifies under Extensive Services. Use the RAI guidelines and consider an early ARD to capture this status if applicable. 


Focus on Respiratory Conditions
 
Residents with COPD, respiratory failure, or requiring oxygen are highly weighted. Track: 

  • Shortness of breath lying flat 
  • Respiratory therapy (7 days/week) 
  • Nurse-delivered interventions like nebulizer or spirometer use 
  • Proper documentation of direct nursing time and vitals 


Function Scores and Interdisciplinary Assessment
 
Many diagnoses qualify for Special Care Low if the nursing function score is ≤11, including: 

  • Multiple sclerosis 
  • Cerebral palsy 
  • Hemiplegia/paresis 
  • Parkinson’s disease
     

Avoid over-reliance on rehab-only data. Consider full-day support needs, especially evenings and nights, when determining GG usual function. 


Mood Interviews Matter
 
Residents with depressive symptoms can have an impact on case mix scores. To ensure accuracy: 

  • Build rapport before the interview 
  • Conduct it privately at eye level 
  • Use visual frequency guides 
  • Normalize emotional responses1*8239 

Final Thoughts: Proactive Preparation Means Fewer Missed Opportunities 

The shift from a RUG-based Medicaid case mix model to the nursing PDPM component isn’t just a technical update—it’s a strategic one. Facilities that prepare thoughtfully will find this system better reflects resident needs and provides more accurate reimbursement.

By refining documentation, training staff, and aligning assessments with clinical realities, skilled nursing providers can navigate this change with confidence and clarity. 

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