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CMS Issues Skilled-Nursing Facility PPS Proposed Rule

For skilled-nursing facility administrators, directors of reimbursement

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The Centers for Medicare & Medicaid Services (CMS) has released its proposed rule on payments to skilled-nursing facilities (SNFs) for fiscal year (FY) 2023. Comments on the proposed rule are due by 2 p.m. (PT) on June 10.   

For FY 2023, CMS proposes a 3.9% update to payment rates, based on a 2.8% SNF market basket update plus a 1.5 % market basket forecast error adjustment, minus a 0.4 % productivity adjustment. CMS also proposes a 4.7 % recalibration of the parity adjustment for the Patient Driven Payment Model (PDPM) to achieve budget neutrality. CMS notes that no parity adjustment was proposed in FY 2022 due to the COVID-19 public health emergency (PHE).   

CMS has developed a revised analysis methodology to better account for the effects of the PHE and now finds that implementation of the PDPM has resulted in an untended increase in payments of approximately 5%. Overall, CMS estimates that the aggregate impact of the proposed payment policies would result in a decrease of approximately $320 million in FY 2023 as compared to FY 2022.   

CMS proposes to adopt a new process measure — Influenza Vaccination Coverage Among Health Care Personnel Measure — to the data set for the SNF Quality Reporting Program (QRP), beginning with the FY 2025 SNF QRP. CMS also proposes to revise the compliance date for certain SNF QRP reporting requirements, including the Transfer of Health Information measure and certain standardized patient assessment data elements that would begin Oct. 1, 2022, to align with other post-acute care settings.  

For the SNF Value-Based Purchasing (VBP) Program, CMS proposes to suppress the SNF 30-day All-Cause Readmission Measure due to the continuing impact of the COVID-19 PHE. CMS also proposes to adopt three new measures — SNF Healthcare Associated Infections Requiring Hospitalization, Total Nursing Hours Per Resident Day, and Discharge to Community – Post-Acute Care for SNFs — into the VBP Program in FY 2026 and FY 2027.   

The proposed rule also includes the following topics:   

  • Nursing Home Staff Turnover Measure: CMS seeks comments on the implementation of a staff turnover measure in the SNF VBP Program.  
  • Coding Infection Isolation: CMS seeks comments on whether current criteria should be adjusted to allow the inclusion of cohorted patients.     
  • CoreQ: Short Stay Discharge Measure: CMS requests information on the inclusion of this measure in the SNF QRP in future years.  
  • Revising Staffing Requirements for Long Term Care Facilities: CMS is seeking input on the effects of direct care staffing requirements and on the establishment of minimum staffing requirements.  
  • Principles for Measuring Equity and Health Care Quality Disparities: The proposed rule requests information on developing and including health equity quality measures for the SNF QRP.  

Additional information on the proposed rule is available in a CMS fact sheet.