The MHA recently submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding the proposed rule to update the Medicare fee-for-service (FFS) inpatient rehabilitation facility (IRF) prospective payment system (PPS) for fiscal year (FY) 2024. These comments were due to the CMS June 2.
The MHA has also drafted comments regarding the FY 2024 Medicare FFS proposed rule to update the inpatient psychiatric facility (IPF) and the proposed rule to update the skilled nursing facility (SNF) PPS. Comments on these rules are due June 5.
The CMS is expected to release final rules to update the IRF, IPF and SNF PPS around Aug. 1, for the Oct. 1, 2023, effective date. The MHA will provide members with an updated Medicare FFS impact analysis following release of the final rules.
Members with questions should contact Vickie Kunz at the MHA.
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 (SNFs) for fiscal year (FY) 2023. Highlights of the proposed rule include:
- A 4% net increase in the federal per diem rate after the marketbasket update and other adjustments. SNFs that fail to comply with CMS quality reporting program (QRP) requirements are subject to a 2 percentage point reduction to the federal rate update.
- A 4.6% “parity adjustment” cut to maintain budget neutrality following implementation of the new Patient Driven Payment Model.
- Adopting one new quality measure in the SNF QRP beginning with the FY 2025 SNF QRP, the Influenza Vaccination Coverage among Healthcare Personnel (NQF # 0431) measure.
- Resuming the reporting of certain measures and patient data that were delayed due to the COVID-19 public health emergency (PHE) beginning Oct. 1, 2023.
- Revising the compliance date for the Transfer of Health Information measures and certain standardized patient assessment data elements that were delayed due to the PHE
- 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 two new measures to the SNF VBP program starting with FYs 2026 and 2027.
- Seeking information on revising the requirements for long term-care facilities to establish mandatory minimum staffing levels.
- Establishing a permanent policy to smooth the impact of year-to-year changes in SNF payments related to changes in the wage index, ensuring that each provider’s wage index is at least 95% of its prior year wage index.
- Implementing a slight increase in the labor-related share of the federal rate from the current 70.4% to 70.7%, which will result in a slight payment increase for SNFs with a wage index greater than 1.0.
- Seeking comments on three topics:
- Quality measures for future years of the SNF QRP.
- The inclusion of CoreQ: Short Stay Discharge Measure in the SNF QRP, which would calculate the percentage of individuals discharged in a six-month period who are satisfied with their SNF stay.
- Strategies to improve measurement of disparities in healthcare outcomes and the agency’s framework to collect, stratify and report quality performance data across the CMS programs, including the SNF QRP.
Comments are due June 10 and should be submitted electronically. The MHA with provide members with an estimated impact analysis and additional detail on the proposed rule within the next few weeks. Members with questions should contact Vickie Kunz at the MHA.
The Centers for Medicare & Medicaid Services (CMS) released a final rule to update the Medicare fee-for-service prospective payment system for skilled nursing facilities (SNFs) for fiscal year (FY) 2022, which begins Oct. 1, 2021.
Key provisions of the rule will:
- Increase the standard federal rate by approximately 1.3% for SNFs that comply with the quality reporting program (QRP) requirements. SNFs that fail to submit data are subject to a 2 percentage point reduction in their annual update.
- Update the diagnosis code mappings used to classify patients into case-mix groups in the Patient Driven Payment Model system implemented in FY 2021.
- Establish a new category of exclusions for the SNF Consolidated Billing policy that specifically creates a new category for blood-clotting factors for the treatment of patients with hemophilia and other bleeding disorders and related items and services.
- Reduce the labor-related share of the federal rate from 71.3% to 70.4%.
- Update the denominator for the Transfer of Health Information to the Patient – Post-Acute Care measure in the SNF QRP to exclude patients discharged home under the care of a home health or hospice provider and add two new quality measures beginning with the FY 2023 QRP:
- The SNF Healthcare Associated Infection Requiring Hospitalization measure.
- The COVID-19 Vaccination Coverage among Healthcare Personnel measure.
- Suppress the SNF 30-Day All-cause Readmission Measure for the FY 2022 SNF value-based purchasing program year due to the public health emergency, which significantly impacted the measure and resulting performance scores.
The CMS continues to review input received on the agency’s Requests for Information on Closing the Health Equity gap and the Fast Healthcare Interoperability Resources in support of Digital Quality Measurement in QRPs, aligning where possible with other quality programs.
The MHA will provide SNFs with an updated impact analysis and summary of the final rule soon. Members with questions should contact Vickie Kunz at the MHA.