The Centers for Medicare & Medicaid Services (CMS) has issued proposed rules for two post-acute care setting prospective payment systems (PPS) for the 2024 federal fiscal year (FFY).
The rules provide payment updates, continued refinement of quality reporting programs (QRPs) and other policy changes for inpatient rehabilitation facilities (IRFs) and skilled-nursing facilities (SNFs). CHA will issue comprehensive summaries for both rules in the near future and will develop comments on behalf of members. Comments on the IRF PPS proposed rule are due on June 2; SNF PPS comments must be submitted by June 5.
IRF PPS Proposed Rule
In the FFY 2024 IRF PPS rule, CMS proposes to update payment rates by 3%, reflecting an IRF market basket update of 3.2 less a proposed 0.2 percentage productivity adjustment. Based on this update, CMS estimates that overall IRF payments for 2024 would increase by 3.7% or $335 million relative to FFY 2023. CMS also proposes several updates to the IRF QRP, including the addition of measures addressing COVID-19 vaccination status for both patients and health care personnel, and the removal of several items that are deemed unnecessary and/or duplicative of other measures. In addition, CMS proposes the start of public reporting on Transfer of Health Information measures.
CMS also proposes to modify the excluded unit regulation that would allow hospitals to establish a new IRF unit and begin getting paid under PPS at any time during the cost reporting. Under current regulations, hospitals could a new Inpatient PPS IRF unit only at the start of a cost reporting period.
SNF PPS Proposed Rule
CMS continues to review feedback received in response to last year’s request for public comment on minimum staffing requirements. CMS plans to review that input along with the results of a study launched in August 2022 collecting quantitative and qualitative evidence on staffing levels. Additionally, CMS plans to propose minimum direct care staffing requirements in rulemaking later this spring.
Payment rates proposed in the FFY 2024 SNF PPS rule would result in an estimated net increase of 3.7% or approximately $1.2 billion as compared to payments made in FFY 2023. The increase is based on a 2.7% SNF market basket increase plus a 3.6% market basket forecast error adjustment and less a 0.2% productivity adjustment and an additional negative 2.3% market basket adjustment resulting from the second phase of the Patient Driven Payment Model parity recalibration.
CMS advances several proposals for changes to the SNF value-based purchasing program (VBP), which rewards SNFs with incentive payments based on the quality of care they provide. New measures proposed for adoption in the VBP in future years include measures addressing nursing staff turnover, discharge function, hospitalizations, falls with major injury and readmission. Additional proposals for changes to SNF VBP administrative methodology and payment percentage, as well as updates on the validation process for quality measures and standardized assessment data are also provided.
CMS also proposes several updates to the SNF QRP, including the addition of measures addressing COVID-19 vaccination status for both patients and health care personnel, a new measure addressing the removal of several items that are deemed unnecessary and/or duplicative of other measures, and to begin public reporting on Transfer of Health Information measures. The addition of two new measures addressing discharge function, and individuals discharge within 100 days are also proposed.