CMS Releases FY 2024 Skilled Nursing Facility Final Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service (FFS) prospective payment system (PPS) for skilled nursing facilities (SNF) for fiscal year (FY) 2024, which begins Oct. 1, 2023. The rule includes:

  • 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 FYs 2023 and 2024, despite opposition from the MHA, the American Hospital Association and others.
  • A 6.4% net increase to the SNF federal per diem base rate for providers that comply with the CMS IPF quality reporting program requirements. Facilities should note that the 6.4% 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 71.1%.
  • Updating the SNF QRP to adopt two new measures, modify the COVID-19 Vaccination Coverage Among Health Care Personnel measure and remove two measures. The CMS did not finalize the CoreQ:Short Stay Discharge Measure, with the agency noting they intend to propose a resident satisfaction or experience measure in the future.
  • Updating the SNF Value-based Purchasing program for future years by
    • Adding the following new measures:
      • Nursing Staff Turnover Measure.
      • Falls with Major Injury (Long-term) Measure.
      • Discharge Function Measure.
      • Long Stay Hospitalization Measure.
    • Replacing the 30-Day All Cause Readmission Measure with the Within Stay Potentially Preventable Readmissions Measure.
    • Adopting a Health Equity Adjustment.
  • Increasing the data completion thresholds to require SNFs to report 100% of the required quality measure data and standardized assessment data collected using the Minimum Data Set tool to at least 90% (instead of 80%) of assessment submitted to the CMS. SNFs that do not meet this requirement will be subject to a two percentage point reduction to their applicable annual payment update.

The MHA will provide SNFs with a facility-specific impact analysis and additional details on the final rule in the near future.

Members with questions should contact Vickie Kunz at the MHA.

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.

MHA Monday Report Aug. 29, 2022

MHA Monday Report

Behavioral Health Legislation Introduced in State House

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New legislation to make changes to the screening process for potential admission to inpatient psychiatric care for behavioral and mental health patients was introduced Aug. 17 in the Michigan House of Representatives. Rep. Graham Filler …


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Game On: FTC Takes on Hospital Consolidation via COPA Dismantling

“The Federal Trade Commission (FTC) issued a scathing 20-page report last Monday criticizing hospital Certificate of Public Advantage (COPA) agreements and urging state lawmakers to suspend their use. …

The FTC has its sights on hospital consolidation: it’s high on the list of industries where its activist’ muscle is likely to be flexed more frequently and effectively. … Like strong bipartisan support for the Hospital Price Transparency Rule, it reflects the FTC’s rejection of hospital claims about inadequate reimbursement by payers including Medicare and Medicaid, price gauging by device, drug and technology suppliers and unfair competition from insurers and niche providers often funded by private investment to optimize profits at the expense of hospitals.

And it offers a solution that’s strong on populist appeal but weak on practical implementation in the current hospital environment: competition vs. consolidation. Regulatory Constraints on hospitals like EMTALA and others are not applied to insurers and retailers who offer a widening range of care management services in direct competition with hospitals. The playing field is increasingly tilted against hospitals.

Paul Keckley, August 22, 2022


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MHA CEO Brian Peters

CMS Releases FY 2023 Final Rule to Update Skilled Nursing Facilities PPS

The Centers for Medicare and Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service (FFS) prospective payment system (PPS) for skilled nursing facilities (SNF) for fiscal year (FY) 2023. Key updates include:

  • A 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 2-year phase-in of the proposed 4.6% negative adjustment despite opposition from the MHA, the American Hospital Association and others.
  • A 5.1% net rate increase after the market basket update and other adjustments, up from the proposed 4% net increase. SNFs that fail to comply with CMS quality reporting program (QRP) requirements are subject to a 2%-point reduction to the federal rate update. Facilities should note that the 5.1% increase will be offset by the negative 2.3% parity adjustment described above.
  • Adopting one new quality measure in the SNF quality reporting program (QRP) beginning in FY 2024: The Influenza Vaccination Coverage among Healthcare Personnel (HCP) (NQF # 0431) measure.
  • Revising the compliance date for certain measures and data reporting that were delayed due to the COVID-19 public health emergency (PHE). Specifically, beginning Oct. 1, 2023, SNFs will be required to collect data on certain standardized patient assessment data elements (SPADEs) and two new quality measures, which are:
    • Transfer of Health Information to the Patient
    • Transfer of Health Information to the Provider
  • Updating the SNF value-based purchasing (VBP) program including continued suppression of the SNF 30-day all-cause readmission measure for the FY 2023 SNF VBP program year for scoring and payment adjustment purposes.
  • Adding new measures to the SNF VBP program starting with the “Skilled Nursing Facility Healthcare Associated Infections Requiring Hospitalizations and “Total Hours per Resident Day Staffing” measures in FY 2026 and the “Discharge to Community” measure in FY 2027.
  • Establishing a permanent policy to limit annual wage index decreases to 5%.
  • Implementing a slight increase in the labor-related share of the federal rate from the current 70.4% to 70.8% which will result in a slight payment increase for SNFs with a wage index greater than 1.0.

The MHA will provide members with an updated impact analysis and additional detail on the final rule in the near future. Members with questions should contact Vickie Kunz at the MHA.

Expansion of Skilled Nursing Services for Aging Population Explored in Webinar

Hospitals and health systems are experiencing a decrease in routine inpatient admissions, prompting development of other services. One of these services is post-acute care, which is expected to grow as the population ages and skilled nursing facilities (SNFs) are expanded and created. To build skilled nursing growth, providers use data focused on referral patterns to develop specialized programs based on patient needs, then promote those specialized services.

The MHA webinar Using Data to Grow Skilled Nursing Facility Admissions will explain each step of this strategic process, including real-world success stories demonstrating the value of this approach.

The webinar is scheduled from 10 to 11 a.m. Nov. 18, and MHA members can register for a $195 connection fee. Members with questions should contact Erica Leyko at the MHA.