BriggsNetNews

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare

It’s a big week for CMS postings and lots of reading materials.  CMS posted this FY2024 SNF PPS Proposed Rule Fact Sheet on April 4, 2024.

On April 4, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that would update Medicare payment policies and rates for skilled nursing facilities under the Skilled Nursing Facility Prospective Payment System (SNF PPS) for fiscal year (FY) 2024. In addition, the proposed rule includes proposals for the SNF Quality Reporting Program (QRP) and the SNF Value-Based Purchasing (VBP) Program for FY 2024 and future years. Finally, this proposed rule would eliminate the requirement for facilities to actively waive their right to a hearing in writing and instead treat the failure to submit a timely hearing request as a constructive waiver.  CMS is publishing this proposed rule consistent with the legal requirements to update Medicare payment policies for SNFs on an annual basis. This fact sheet discusses the major provisions of the proposed rule.

These actions support the Administration’s plan to improve safety and quality of care in nursing homes, and CMS remains committed to proposing minimum staffing standards for nursing facilities later this spring.

• Minimum Staffing Requirements
• FY 2024 Proposed Updates to the SNF Payment Rates
• Proposed Changes in PDPM ICD-10 Code Mappings
• Proposed Changes to the Skilled Nursing Facility Quality Reporting Program (SNF QRP)
• Adoption of the Discharge Function Score (DC Function) measure;
• Adoption of the CoreQ: Short Stay Discharge (CoreQ: SS DC) measure;
• Adoption of the COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date (Patient/Resident COVID-19 Vaccine) measure;
• Modify the COVID-19 Vaccination Coverage among Healthcare Personnel (HCP COVID-19 Vaccine) measure;
• Remove the Application of Percent of Long-Term Care Hospital (LTCH) Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (Application of Functional Assessment/Care Plan) measure;
• Remove the Application of the IRF Functional Outcome Measures: Change in Self-Care Score for Medical Rehabilitation Patients (Change in Self-Care Score) measure; and the Change in Mobility Score for Medical Rehabilitation Patients (Change in Mobility Score) measure;
• Increase the SNF QRP Data Completion thresholds for the Minimum Data Set (MDS) Data Items beginning with the FY 2026 SNF QRP;
• Begin the public reporting of the Transfer of Health Information to the Provider—PAC Measure and the Transfer of Health Information to the Patient—PAC Measure.
• Proposed Changes to the Skilled Nursing Facility Value-Based Purchasing (SNF VBP) Program
• Adoption of the Nursing Staff Turnover Measure;
• Adoption of the Discharge Function Score measure;
• Adoption of the Long Stay Hospitalization Measure per 100 residents;
• Adoption of the Percent of Residents Experiencing One or More Falls with Major Injury (Long Stay);
• Replacement of the Skilled Nursing Facility 30-Day All-Cause Readmission Measure (SNFRM) with the Skilled Nursing Facility Within Stay Potentially Preventable Readmissions (SNF WS PPR);
• Adoption of a Health Equity Adjustment in the SNF VBP Program that rewards SNF that perform well and whose resident population during the applicable performance period includes at least 20% of residents with dual eligibility status;
• Increase the payback percentage policy under the SNF VBP program from current 60% to a level such that the bonuses provided to the high performing, high duals SNFs do not come at the expense of the other SNFs;
• Update administrative methodology policies that are required to address the changes needed to accommodate the proposed addition of quality measures into the SNF VBP Program’s scoring methodology;
• Addition of the audit portion of the validation process for MDS-based measures beginning with the FY 2027 program year and FY 2025 performance year.
• Proposed Changes to Civil Money Penalties (CMP): Waiver of Hearing, Reduction of Penalty Amount (§ 488.436)

The proposed rule can be downloaded from the Federal Register here; the unpublished PDF version here (312 pages).   Monday, April 10, 2023 is the date scheduled for publication in the Federal Register. Stakeholder comments must be submitted by June 5, 2023.

You find the proposed FY 2024 SNF PPS Proposed Wage Index Tables here.

The Fact Sheet, Proposed Rule and Wage Index Tables (in their entirety) are must-reads for your team and colleagues. I encourage you to submit your comments as CMS reviews all stakeholder comments. Your voice is important!