CHA DataSuite has issued analyses of the federal fiscal year (FFY) 2024 wage index and occupational mix data and two proposed rules — the skilled-nursing facility (SNF) prospective payment system (PPS) and the long-term care hospital (LTCH) PPS.
FFY 2024 Final Wage Index and Occupational Mix Data
This analysis has been designed in the Business Intelligence platform. The data analyzed are “final” and are the third of three wage and occupational mix data public use files (PUFs) that CMS issued to develop the hospital wage index for FFY 2024.
It is extremely important that hospitals review these wage data. Under CMS’ hospital wage index development timetable, hospitals have until May 26 to verify their data and submit correction requests with supporting documentation to both CMS and their Medicare Administrative Contractor (MAC) to:
- Correct errors due to CMS or MAC mishandling of the “final” wage data posted in the April 28 PUF.
- Dispute data corrections made by CMS of which the hospital has been notified between March 19 and May 12 that do not arise from a hospital’s request for revisions.
Appeals for the FFY 2024 wage index cycle must be submitted with all supporting documentation on the Wage Index Appeals module in the Medicare Electronic Application Request Information System (MEARIS). To ensure compatibility, supporting documentation should be a PDF or a Word file and spreadsheets should be in Excel. If a hospital is unable to submit an appeal using MEARIS, the hospital may submit it via email to email@example.com.
Data corrections made by CMS of which the hospital has been notified on or after May 13 may be appealed to the Provider Reimbursement Review Board.
Changes to the data will be limited to situations involving errors by CMS or the MAC that the hospital could not have known about before the review of the “final” April PUFs. Data that were incorrect in the preliminary revised wage index data PUFs, but for which no correction requests were received by the Feb. 15 deadline will not be changed at this stage for inclusion in the wage index.
FFY 2024 Medicare SNF PPS Proposed Rule
This analysis is intended to show providers how Medicare fee-for-service payments will change from FFY 2023 to FFY 2024 based on the policies set forth in the proposed rule. A detailed summary of the proposed rule is available for CHA members.
SNF PPS payments for FFY 2023 are based on FFY 2021 SNF claims sourced from the calendar year (CY) 2020-2021 SNF Standard Analytical Files Limited Dataset 100% claims data. SNF PPS payments for FFY 2024 are calculated by applying all update factors to the FFY 2023 totals. Wage indexes, labor shares, and per-diem payment rates are from the FFY 2022-2023 final rule and the FFY 2024 proposed rule. SNF value-based purchasing (VBP) adjustments are from the final FFY 2023 SNF VBP performance from Nursing Home Compare, SNF’s estimated FFY 2024 revenue, prior to the application of SNF VBP.
Comments on the proposed rule are due to CMS by June 5 and can be submitted electronically.
FFY 2024 Medicare LTCH PPS Proposed Rule
This analysis is intended to show how Medicare LTCH fee-for-service payments may change from FFY 2023 to FFY 2024 based on the policies set forth in the proposed rule. The impact of site-neutral payments for certain cases has been incorporated into this analysis. A detailed summary of the proposed rule is available for CHA members.
The Bipartisan Budget Act mandates an inpatient prospective payment system equivalent payment rate for ALL discharges for LTCHs with fewer than 50% of their cases eligible for LTCH standard payment. This percentage and estimated impact if the LTCH fails to meet the threshold is displayed where applicable.
Comments on the proposed rule are due to the Centers for Medicare & Medicaid Services (CMS) by June 9, and can be submitted electronically by using the website’s search feature to search for file code “1785-P”.
Email DataSuiteReports@calhospital.org with questions about any of the analyses.