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CHA Comments on Proposed SNF Case-Mix Changes

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CHA has submitted the attached comment letter on the Centers for Medicare & Medicaid Services (CMS) advance notice of proposed rulemaking (ANPRM) outlining potential revisions to the skilled-nursing facility (SNF) prospective payment system (PPS) case-mix methodology. Overall, CHA supports CMS’ proposal to revise the SNF PPS to more closely align with patients’ medical and rehabilitative needs, and to reflect the intensity of services provided to medically complex patients. Additionally, CHA requests that CMS take steps to include adequate controls and oversight to ensure that patients continue to receive medically necessary services. CHA also urges CMS to adopt a budget-neutral approach and include a transition period for implementation of associated reimbursement changes.