CHA submitted comments on the federal fiscal year (FFY) 2023 skilled-nursing facility (SNF) prospective payment system proposed rule issued by the Centers for Medicare & Medicaid Services (CMS).
In the letter, CHA expressed disappointment in the proposed market basket update as it is wholly inadequate relative to the input cost inflation experienced by SNFs. CHA believes the assumptions underpinning the productivity adjustment are fundamentally flawed and asked CMS to work with Congress to permanently eliminate this unjustified reduction to hospital payments and for CMS to use its section 1135 waiver authority to remove the productivity adjustment for any fiscal year that was covered under public health emergency determination from the calculation of market basket for FFY 2023 and any year thereafter.
CHA raised concerns about data related to the patient-driven payment model parity adjustment and asked CMS to delay the adjustment until the data analysis can be further refined to eliminate the impact of the COVID-19 pandemic.
In comments, CHA urged CMS to reconsider its proposal to begin data collection on Oct. 1, 2023, for the FFY 2024 SNF quality reporting program (QRP), for certain measures previously finalized for the SNF QRP. CHA also provided detailed requests on proposals in the SNF value-based purchasing program.
Additionally, CHA provided feedback on several requests for information, including health equity and minimum staffing levels for nursing.