CHA News

CMS Issues FFY 2020 Skilled-Nursing Facility PPS Proposed Rule

For CEOs, CFOs, Post-Acute Care Executives

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The Centers for Medicare & Medicaid Services (CMS) has issued the federal fiscal year (FFY) 2020 proposed rule for the skilled-nursing facility prospective payment system (SNF PPS). The provisions in the proposed rule, if finalized, would be effective Oct. 1, 2020.

CHA is reviewing the proposed rule and will issue a summary in the coming weeks. CHA will also host a member forum to review the proposed rule’s provisions and to develop comments, which are due on June 18. 

Following are highlights of the proposed rule.  

Payment Provisions

CMS proposes to increase net payments by 2.5 percent, or $887 million, as compared to FFY 2019, the result of a 3 percent market-basket update, offset by a statutorily mandated 0.5 percent cut for productivity.  

As provided in the FFY 2019 final rule, CMS will implement a revised case-mix methodology and replace the current resource use group (RUG) methodology with the patient driven payment model (PDPM) on Oct. 1, 2019.  The PDPM uses ICD-10 codes to classify patients into clinical categories, to ensure that SNFs have timely information. 

CMS also proposes to expand the collection of patient assessment data and data used to calculate quality measures using the minimum data set (MDS) to include all patients, regardless of payer source. 

Implementation of Standardized Patient Assessment Data Elements (SPADEs)

Among CMS’ most notable proposals is the adoption of several standardized patient assessment data elements (SPADEs), as well as several new data elements related to social determinants of health, beginning Oct. 1, 2020. 

Definition of Group Therapy

CMS proposes to change the definition of group therapy to align with the definition used in the inpatient rehabilitation facility (IRF) PPS — therapy that consists of two to six patients doing the same or similar activities. CMS believes that aligning the group therapy definition will support consistency in payment policies across post-acute care settings and create opportunities for site-neutral payments. 

Quality Reporting

CMS proposes to adopt two new process measures to the SNF Quality Reporting Program (QRP), addressing the “Transfer of Health Information” domain as required by the Improving Medicare Post-Acute Care Transformation Act. Data collection on these measures would begin on Oct. 1, 2020, and the measures would be incorporated into the SNF QRP in FFY 2022. CMS also proposes to modify the existing “Discharge to Community” measure to exclude baseline nursing home residents. 

Value-Based Purchasing

The SNF Value-Based Purchasing (VBP) Program, which provides incentive payments based on performance, is currently based on an all-cause measure of hospital readmissions. In the future, it will transition to a measure of potentially preventable hospital readmissions. CMS proposes several updates related to public reporting requirements and timelines for review and correction.