CHA News

CMS Issues Post-Acute Care Payment Proposed Rules

What’s happening: The Centers for Medicare & Medicaid Services (CMS) issued its proposed payment policies for inpatient rehabilitation facilities (IRFs), skilled-nursing facilities (SNFs), and hospices for federal fiscal year (FFY) 2025.  

What else to know: Comments on the proposed rules are due to CMS by 2 p.m. (PT) on May 28. 

The proposed rules provide payment updates, continued refinement of quality reporting programs (QRPs), and other policy changes for IRFs, SNFs, and hospices.  

IRF Proposals  

  • Update the IRF prospective payment system (PPS) payment rates by 2.8% based on the proposed IRF market basket update of 3.2%, less a proposed 0.4% point productivity adjustment. 
  • Adopt four new items in the IRF-PAI (patient assessment instrument) as social determinants of health (SDOH) standardized patient assessment data elements.  
  • Modify the transportation item under the SDOH category in IRF quality reporting program (QRP). 
  • Remove the “Admission Class” assessment item from the IRF-PAI item set. 
  • Requests feedback on potential measurement concepts and the creation of a star rating system for the IRF QRP.  

SNF Proposals  

  • Update the SNF PPS rates by 4.1% based on the proposed SNF market basket of 2.8%, plus a 1.7% market basket forecast error adjustment, and a negative 0.4% productivity adjustment. 
  • Several changes to Patient-Driven Payment Model (PDPM) ICD-10 code mappings. 
  • Revise CMS’ existing nursing home enforcement authority, including expanding its ability to impose financial penalties. 
  • Add four new SDOH items and modify one SDOH assessment item for the SNF QRP. 
  • Modify the transportation item under the SDOH category in the SNF QRP. 
  • Require SNFs participating in the SNF QRP to participate in a minimum data set validation process. 
  • Adopt a measure retention and removal policy to the SNF value-based purchasing program, update the case-mix methodology for the total nurse staffing measure and a review and correction policy update. 

Hospice Proposals  

  • Payment increase of 2.6% (an estimated increase of $705 million in payments from FY 2024) 
  • Hospice cap of $34,364.85
  • Addition of two new process measures to the hospice QRP
  • Adoption and implementation of the HOPE patient-level data collection tool, beginning with FY 2025, and functionally replace the existing Hospice Item Set structure upon implementation 
  • Request for input on potential data collection items related to four SDOHs that may be relevant to the hospice setting
  • Changes to the Hospice  Consumer Assessment of Healthcare Providers and Systems Survey based on the results of a mode experiment conducted in 2021

CHA will issue comprehensive summaries of the rules in the near future.