Proposal Would Delay Quality Reporting for Long-term Care, Inpatient Rehab Facilities

The Centers for Medicare & Medicaid Services (CMS) recently included proposals related to the quality reporting programs for long-term care hospitals (LTCHs) and inpatient rehabilitation facilities (IRFs) in its proposed rule to update the Medicare fee-for-service prospective payment system for home health agencies (see related article). LTCHs and IRFs were initially scheduled to begin reporting two new quality measures Oct. 1, 2020, including Transfer of Health Information to the Provider and Transfer of Health Information to the Patient, as well as several standardized patient assessment data elements (SPADES).

Due to the COVID-19 public health emergency (PHE), the CMS declined to release updated versions of the patient assessment tools necessary for reporting this information and delayed the compliance date for reporting these items until Oct. 1 of the year that is at least one full fiscal year after the end of the COVID-19 PHE. The CMS proposes to require reporting of these measures and SPADES beginning Oct. 1, 2022, since COVID-19 cases and deaths have declined. The MHA encourages LTCHs and IRFs to submit comments to the CMS regarding this provision by Aug. 27. Members with questions should contact Vickie Kunz at the MHA.

Skilled Nursing Facility Prospective Payment System Proposed Rule Released

The Centers for Medicare & Medicaid Services (CMS) released a proposed rule to update the Medicare fee-for-service prospective payment system (PPS) for skilled nursing facilities (SNFs) for fiscal year (FY) 2022, which begins Oct. 1, 2021.

Key provisions of the proposal would:

  • Increase the standard federal rate by a net 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 in the Patient Driven Payment Model case-mix system implemented in FY 2021.
  • Reduce the labor-related share of the federal rate from 71.3% to 70.1%.
  • Modify 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 (PHE), which significantly impacted the measure and resulting performance scores.
  • Reduce the number of quarters for publicly reporting SNF QRP measures due to the PHE.

The CMS is working to make healthcare quality more transparent to consumers and providers. Included in the proposed rule is a request for input on ways to attain health equity for all patients through policy solutions as demonstrated through the adoption of the standardized patient assessment data elements (SPADEs) in the FY 2020 SNF final rule. These elements include several social determinants of health. The CMS seeks feedback on the possibility of expanding measure development and the collection of other SPADEs that address gaps in health equity in the SNF PPS. The CMS also seeks input on the potential use of Fast Healthcare Interoperability Resources in support of Digital Quality Measurement in QRPs, aligning with other quality programs where possible.

The CMS will accept comments on the proposed rule until June 7. The MHA will provide SNFs with an estimated impact analysis and summary of the proposed rule soon. Members with questions should contact Vickie Kunz at the MHA.

Comments Being Accepted on Inpatient Rehabilitation Facilities Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) released a proposed rule to update the Medicare fee-for-service prospective payment system for inpatient rehabilitation facilities (IRFs) for fiscal year (FY) 2022, which begins Oct. 1, 2021.

Key provisions of the proposal would:

  • Increase the standard federal rate by 2.5% from $16,856 to $17,273 for facilities that comply with the IRF quality reporting program (QRP). Facilities that fail to comply are subject to a 2 percentage point reduction.
  • Increase the cost outlier threshold by 16% from $7,906 to $9,192, resulting in fewer cases qualifying for an outlier payment.
  • Modify the IRF QRP by:
    • Proposing the addition of the COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) measure, requiring IRFs to report HCP vaccinations in their facilities.
    • Updating the denominator for the Transfer of Health Information to the Patient-Post Acute Care quality measure to exclude patients discharged home under the care of a home health or hospice provider.
    • Updating the number of quarters of data used for public reporting to account for the COVID-19 public health emergency reporting exception granted for Jan. 1 – June 30, 2020.

As it works to make healthcare quality more transparent to consumers and providers, the CMS is seeking input on ways to attain health equity for all patients through policy solutions, as demonstrated by the adoption of standardized patient assessment data elements (SPADEs). These data elements include several social determinants of health that were finalized in the FY 2020 final rule for the IRF QRP. Through a Request for Information within the proposal, the CMS is seeking comment on expanding measure development and the collection of other SPADEs that address health equity gaps. The agency also seeks feedback on its plans to define digital quality measures for the IRF QRP and the potential use of fast healthcare interoperability resources within the IRF QRP, aligning with other quality programs where possible.

The CMS will accept comments on the proposed rule until June 7. The MHA will provide IRFs with an estimated impact analysis and summary of the proposed rule within the next month. Members with questions should contact Vickie Kunz at the MHA.