News

CMS Releases FY 2025 Proposed Rule: SNFs In Line to Receive 4.1% Reimbursement Increase  

WHAT YOU NEED TO KNOW

On March 28th CMS issued Fiscal Year 2025 Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities proposed rule. This proposal contains many areas of importance and significance for SNF providers specifically as it relates to payment, quality, civil monetary penalties, and more.

Key elements of the proposed rule include:

PAYMENT UPDATE

•  CMS estimates the aggregate impact of payment policies would result in an increase of $1.3 billion, or 4.1%, in Medicare Part A payments to SNFs in FY 2025
• An additional $187 million in reductions is estimated based on the SNF VBP program

PAYMENT-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 4 new Social Determinants of Health (SDOH) items including items related to Living Situations, Food, and Utilities

SNF VALUE-BASED PURCHASING (VBP PROGRAM)

• CMS did not propose any new measures or changes to existing measures

NURSING HOME ENFORCEMENT

• CMS is proposing to expand Civil Monetary Penalties (CMPs) as follows:
  • Expand circumstances in which Per Instance CMPs can be imposed
  • Revising the definition of "instance" or "instance of non-compliance" such that each instance of noncompliance would be sufficient to constitute deficiency
  • Proposing to revise CMS authority to impose both a Per Instance CMP and a Per Day CMP when surveyors identify non-compliance
  • Proposing to allow for each instance of non-compliance (Per Instance or Per Day) to be imposed, regardless of whether the deficiencies constitute immediate jeopardy

REQUEST FOR INFORMATION
CMS routinely submits Requests for Information (RFI) from stakeholders regarding potential future changes to payment and regulations; of note, CMS submitted a RFI related to potential updates to the Non-Therapy Ancillary (NTA) component of PDPM. Specifically, CMS is considering revising the list of qualifying NTA services/conditions as well as the point value assigned.

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