On July 29, 2022, the Facilities for Medicare & Medicaid Companies (CMS) issued a ultimate rule that updates Medicare fee insurance policies and charges for expert nursing services (SNFs) and enacts modifications to the SNF High quality Reporting Program and the SNF Worth-Primarily based Buying Program starting in FY 2023.
SNF Cost Charges and PDPM Changes
Nursing properties will obtain a web 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 Cost 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 Cost Mannequin (PDPM).
The PDPM was launched in late 2019 as a brand new mannequin by which to categorise SNF sufferers beneath the SNF Potential Cost System. The aim of the PDPM was to get rid of sure incentives related to classifying sufferers beneath the prior case-mix classification mannequin, Useful resource Utilization Group, Model 4 (RUG-IV), in an effort to enhance reimbursements, in addition to to enhance the general accuracy and appropriateness of SNF funds. PDPM classifies sufferers into fee teams primarily based on particular, data-driven affected person traits. The implementation of the PDPM was supposed to be “funds impartial,” nevertheless, as talked about, finally resulted in an unintended enhance in funds. As a way to offset these unintended funds, CMS plans to recalibrate the PDPM parity adjustment steadily over the subsequent 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 applied solely short-term insurance policies to offset vital modifications to funds because of modifications to the wage index. The applying of a everlasting cap is a vital step as yr over yr modifications to the wage index typically create instability and negatively influence suppliers. Furthermore, such modifications 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 detrimental negative effects to suppliers ensuing from reductions to the wage index.
Expert Nursing Facility High quality Reporting Program
The ultimate rule additionally offers 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 usually decrease in long-term care settings, akin to SNFs, when in comparison with different care settings. As CMS defined, residents of long-term care services typically have higher susceptibility to influenza because of common frailty and comorbidities, shut contact with different residents, interactions with guests, and publicity to workers who rotate between a number of services. Due to this fact, by means 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-Primarily based Buying Program
The SNF value-based buying (VBP) program rewards nursing services with incentive funds primarily based 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 in the course of the COVID-19 public well being emergency that allows it to suppress using the SNFRM for functions of scoring and fee changes within the SNF VBP Program if CMS determines that circumstances attributable to COVID-19 have affected the measure and the ensuing efficiency scores considerably. And, CMS utilized this coverage for FY 2023. Citing issues of the impact of the COVID-19 pandemic on CMS’ means to precisely assess efficiency on the SNFRM, the present ultimate rule offers that facility readmission measures won’t 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 means to measure the efficiency of expert nursing services on the SNFRM, and thus on its means to make use of the SNFRM to calculate funds for the FY 2023 program yr. Particularly, the validity of such information is compromised by the mix of serious variation in COVID-19 case charges throughout the U.S, modifications 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 won’t 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 further efficiency measures.
Staffing Ranges
Earlier this yr, CMS sought public suggestions on its proposal to require minimal staffing ranges in nursing properties and to probably 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’s going to suggest rulemaking on this challenge subsequent yr, after additional learning “the extent and sort of staffing wanted to make sure secure and high quality care.”
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