On July 29, 2022, the Facilities for Medicare & Medicaid Companies (CMS) issued a closing rule that updates Medicare fee insurance policies and charges for expert nursing amenities (SNFs) and enacts adjustments to the SNF High quality Reporting Program and the SNF Worth-Based mostly Buying Program starting in FY 2023.
SNF Fee Charges and PDPM Changes
Nursing houses will obtain a internet enhance of two.7%, or $904 million, in Medicare Half A funds in FY 2023 as in comparison with FY 2022. Apparently, this enhance stands in direct distinction to the advice of the Medicare Fee Advisory Fee to scale back the Medicare base fee charges for SNFs by 5%. Furthermore, CMS itself had initially proposed a lower of $320 million in mixture Medicare Half A funds to SNFs throughout FY 2023, though the lower was partially as a way to offset the unintended enhance in funds of roughly $1.7 billion per yr that resulted from the implementation of the Affected person Pushed Fee Mannequin (PDPM).
The PDPM was launched in late 2019 as a brand new mannequin by which to categorise SNF sufferers beneath the SNF Potential Fee System. The aim of the PDPM was to remove sure incentives related to classifying sufferers beneath the prior case-mix classification mannequin, Useful resource Utilization Group, Model 4 (RUG-IV), with a purpose to enhance reimbursements, in addition to to enhance the general accuracy and appropriateness of SNF funds. PDPM classifies sufferers into fee teams based mostly on particular, data-driven affected person traits. The implementation of the PDPM was meant to be “price range impartial,” nonetheless, as talked about, finally resulted in an unintended enhance in funds. To be able to offset these unintended funds, CMS plans to recalibrate the PDPM parity adjustment step by step over the following two years.
Everlasting Cap on Wage Index Lower
In efforts to mitigate year-to-year instability in suppliers’ wage indexes, CMS finalized a everlasting 5% cap on annual wage index decreases in future years, the results of which will probably be that geographic space’s wage index wouldn’t be lower than 95% of its wage index calculated within the prior FY whatever the circumstances inflicting the decline. Notably, previously, CMS has carried out solely short-term insurance policies to offset vital adjustments to funds on account of adjustments to the wage index. The appliance of a everlasting cap is a vital step as yr over yr adjustments to the wage index typically create instability and negatively affect suppliers. Furthermore, such adjustments are sometimes unpredictable, and as CMS defined within the proposed rule, the significance to payers of sustaining predictability in Medicare funds is apparent. CMS’ implementation of a everlasting 5% cap on annual wage index decreases is meant to not solely enhance the predictability of SNF PPS funds for suppliers, but in addition mitigate unfavourable negative effects to suppliers ensuing from reductions to the wage index.
Expert Nursing Facility High quality Reporting Program
The ultimate rule additionally supplies for a brand new course of measure for the SNF High quality Reporting Program (QRP)—the Influenza Vaccination Protection amongst Healthcare Personnel measure. Because the identify suggests, the brand new measure assesses the speed of influenza vaccination protection amongst well being care personnel in SNFs starting with the FY 2024 SNF QRP. Notably, influenza vaccination protection amongst well being care personnel is often decrease in long-term care settings, reminiscent of SNFs, when in comparison with different care settings. As CMS defined, residents of long-term care amenities typically have higher susceptibility to influenza on account of normal frailty and comorbidities, shut contact with different residents, interactions with guests, and publicity to workers who rotate between a number of amenities. Due to this fact, by way of this new measure, CMS emphasizes the significance of monitoring and reporting influenza vaccination charges amongst well being care personnel in SNFs.
Suppression of Readmission Measure for Expert Nursing Facility Worth-Based mostly Buying Program
The SNF value-based buying (VBP) program rewards nursing amenities with incentive funds based mostly on the standard of care they supply to Medicare beneficiaries, as measured by efficiency on a single measure of hospital readmissions—the Expert Nursing Facility 30-Day All-Trigger Readmission Measure (SNFRM).
In a previous rule, CMS adopted a coverage all through the COVID-19 public well being emergency that permits it to suppress the usage of the SNFRM for functions of scoring and fee changes within the SNF VBP Program if CMS determines that circumstances brought on by COVID-19 have affected the measure and the ensuing efficiency scores considerably. And, CMS utilized this coverage for FY 2023. Citing considerations of the impact of the COVID-19 pandemic on CMS’ skill to precisely assess efficiency on the SNFRM, the present closing rule supplies that facility readmission measures is not going to be included as a part of the efficiency scoring for FY 2023. CMS defined that the pandemic has had “direct, vital, and persevering with results” on its skill to measure the efficiency of expert nursing amenities on the SNFRM, and thus on its skill to make use of the SNFRM to calculate funds for the FY 2023 program yr. Particularly, the validity of such knowledge is compromised by the mix of serious variation in COVID-19 case charges throughout the U.S, adjustments in hospitalization patterns in FY 2021, and fewer admissions to SNFs. CMS suggested that efficiency on this measure will nonetheless be reported publicly, it simply is not going to have an effect on fee, in FY 2023.
Along with suppressing the SNFRM for the FY 2023 SNF VBP Program for the aim of scoring and fee changes, CMS will implement particular scoring procedures for FY 2023 and adopted extra efficiency measures.
Earlier this yr, CMS sought public suggestions on its proposal to require minimal staffing ranges in nursing houses and to doubtlessly tie sure funds to the extent of workers turnover, which CMS notes has been linked to affected person high quality of care. Whereas the ultimate rule doesn’t handle this challenge, CMS suggested that it’ll suggest rulemaking on this challenge subsequent yr, after additional finding out “the extent and sort of staffing wanted to make sure secure and high quality care.”
When you have any questions concerning the affect of the above, please attain out to the beneath.