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CHA Provides Summary of Proposed SNF PPS Case-Mix Changes

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CHA has issued the attached summary, prepared by Health Policy Alternatives, of a recent Centers for Medicare & Medicaid Services (CMS) advance notice of proposed rule-making (ANPRM) outlining potential revisions to the skilled-nursing facility (SNF) prospective payment system (PPS) case-mix methodology. CMS seeks feedback on the changes, which it is considering including in federal fiscal year (FFY) 2019 rulemaking. 

CMS proposes to replace the current resource utilization groups (RUGs) case-mix system with a new methodology, the Resident Classification System, Version  l (RCS-I). RCS-I would aim to pay SNFs accurately based on beneficiary complexity and required care, and avoid incentivizing therapy delivery by payment policy. Notably, the therapy component would be case-mix adjusted based on resident performance on selected functional status measures, rather than on documented therapy utilization. Additionally, CMS proposes to create a non-therapy ancillary services component, separate from the nursing component. 

The ANPRM analyzes the relative anticipated impact related to numerous facility and beneficiary factors. Under this proposal, CMS estimates that overall reimbursement for hospital-based SNFs would increase by 15.8 percent, while payments to free-standing SNFs would decrease by 0.5 percent.     

Comment on the proposed rule are due on August 25, at 2 p.m. (PT).