News

BACKGROUND

The Centers for Medicare and Medicaid Services (CMS) are required to update the Medicare payment rates and quality programs on an annual basis. Each April, CMS publishes a proposed rule for the upcoming fiscal year (FY) and opens a comment period for stakeholders to review and provide comments to CMS before releasing the final rule.

WHAT YOU NEED TO KNOW

On April 4th CMS issued the proposed rule CMS-1779-P for FY 2024. This proposed rule contains many areas of importance and significance for SNF providers specifically as it relates to payment, quality, staffing, and more.

Preferred Therapy Solutions is thoroughly reviewing the proposed rule and has planned an in-depth webinar for April 19th.

Key elements of the proposed rule include:

PAYMENT UPDATE

• CMS estimates the aggregate impact of payment policies would result in an increase of approximately $1.2 billion in Medicare Part A payments to SNFs in FY 2024
• The actual payment update for FY 2024 is a 6.1% net market basket increase which is offset by a 2.3% decrease in SNF PPS rates as a result of the second phase of the PDPM parity adjustment calibration
• An additional $185 million in reductions is estimated based on the SNF VBP program

PATIENT-DRIVEN PAYMENT MODEL

• CMS is proposing several changes to the PDPM ICD-10 code mappings and lists

SNF QUALITY REPORTING PROGRAM (QRP)

• CMS is proposing to adopt three new quality measures to become part of the SNF QRP:
  • Discharge Function Score measure for FY 2025
  • CoreQ: Short Stay Discharge measure for FY 2026
  • COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date measure for FY 2026
• CMS is proposing to modify the COVID-19 Vaccination Coverage Among Healthcare Personnel measure for FY 2025
• CMS is proposing to remove three quality measures from the SNF QRP:
  • Application of Percent of LTC Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function for FY 2025
  • Changes in Self-Care Score for Medical Rehabilitation Patients for FY 2025
  • Changes in Mobility Score for Medical Rehabilitation Patients for FY 2025
• CMS is proposing to increase the completion thresholds such that 100% of the required quality measure data is collected on at least 90% assessments submitted to CMS beginning with FY 2026; non-compliant facilities would be subject to a 2% payment reduction

SNF VALUE-BASED PURCHASING (VBP PROGRAM)

• CMS is  proposing the adoption of four new quality measures: Nursing Staff Turnover measure, Discharge Function Score Measure, Long Stay Hospitalization Measure per 100 Residents, and Percent of Residents Experiencing One or More Falls with Major Injury (Long Stay)
• CMS is proposing the replacement of the SNF 30-day All-Cause Readmission Measure with SNF Within-Stay Potentially Preventable Readmissions (SNF WS PPR)
• Other SNF VBP proposed changes include:
  • Rewarding SNFs that perform well and whose resident population contains at least 20% dual eligibility status
  • Increasing the payback percentage from 60% to 66%

MINIMUM STAFFING REQUIREMENTS

Last year’s Proposed Rule solicited comments from stakeholders regarding the setting of minimum staffing requirements and it was widely expected CMS would propose a staffing requirement standard for SNFs in this year’s Proposed Rule but they did not. CMS stated they are continuing to collect quantitative and qualitative evidence on staffing levels and again are soliciting feedback from stakeholders.

Finally, Preferred Therapy Solutions will be submitting comments and feedback to CMS to advocate for therapy services, SNF providers, and most importantly, the residents we are privileged to serve. We encourage all providers to do the same! Join our webinar on April 19th to learn more about the proposed rule and how to advocate for our industry and patients.

Preferred Therapy Solutions continues to provide vital information that may impact rehabilitation management, reimbursement policies, and clinical programs, supported by compliance and regulatory requirements that are necessary for a thorough understanding of practices and procedures. If you have any questions, contact Matt Nash, Vice President of Business and Development at mnash@preftherapy.com