CMS Releases FY 2024 Skilled Nursing Facility Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service prospective payment system for skilled nursing facilities (SNF) for fiscal year (FY) 2024, beginning Oct. 1, 2023. The CMS did not propose new minimum staffing requirements for SNFs in this rule but restated the agency’s intention to propose such requirements in separate rulemaking this spring. Key provisions of the proposal include:

  • Continuation of the negative 2.3% parity adjustment to the Patient Driven Payment Model (PDPM) case mix indices following implementation of the PDPM to maintain budget neutrality with the prior RUG-IV case-mix system. The CMS finalized a two-year phase-in of the proposed 4.6% negative adjustment for FY 2023 and 2024 despite opposition from the MHA, the American Hospital Association and others.
  • A 3.7% net increase to the SNF federal per diem base rate for providers that comply with the CMS IPF quality reporting program (QRP) requirements. Facilities should note that the 3.7% net increase will be offset by the negative 2.3% parity adjustment described above.
  • A slight increase in the labor-related share from the current 70.8% to 71%.
  • Changes to the SNF QRP including:
    • Adopting one new quality measure: The Discharge Function Score (DC Function).
    • Modifying the COVID-19 Vaccination Coverage Among Health Care Personnel measure.
    • Removing three measures:
      • Application of Percent of Long-Term Care Hospitals Patients with an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function.
      • The Application of the IRF Functional Outcome Measure: Change in Self-Care Score for Medical Rehabilitation Patients.
      • The Application of the IRF Functional Outcome Measure: Change in Mobility Score for Medical Rehabilitation Patients.
    • Adopting four new measures for the SNF Value-based Purchasing (VBP) program:
      • Nursing Staff Turnover Measure.
      • Discharge Function Score Measure.
      • Long Stay Hospitalization Measure per 100 residents.
      • Percent of Residents Experiencing One or More Falls with Major Injury (Long-Stay).
    • Replacing the 30-Day All Cause Readmission Measure with Within Stay Potentially Preventable Readmissions Measure.
    • Adoption of Health Equity Adjustment.

The MHA will provide SNFs with a facility-specific impact analysis and additional details on the proposed rule in the near future. The MHA also encourages members with SNF operations to review the proposed rule, provide comments to Vickie Kunz at the MHA by May 25 and submit comments to the CMS by June 5. The CMS is expected to release a final rule around Aug. 1, for an Oct. 1, 2023, effective date.  Members with questions should contact Vickie Kunz at the MHA.