On March 28, 2024, CMS issued a proposed rule (Proposed Rule) for fiscal year (FY) 2025 that would update Medicare payment policies and rates for skilled nursing facilities (SNFs) under the SNF Prospective Payment System (PPS). Under the Proposed Rule, CMS presented several updates, revisions, and changes to Medicare payment policies. Some of the proposed changes are highlighted below, and interested stakeholders are encouraged to submit comments. Comments are due by 5:00 PM ET on May 28, 2024.
SNF Payment Rates
In the Proposed Rule, CMS proposes an update to the SNF PPS rates by 4.1% based on the proposed SNF market based of 2.8%, plus a 1.7% market basket forecast error adjustment, and a negative 0.4% productivity adjustment. SNF Value-Based Purchasing Program reductions, estimated to total $196.5 million in FY 2025, are not included in these figures. Additionally, CMS proposed to update the Skilled Nursing market basket base year from the current base year 2018 to a new base year of 2022. Further, the SNF PPS wage index would be updated using Core-Based Statistical Areas (CBSAs) to enhance wage accuracy.
Patient-Driven Payment Model (PDPM) ICD-10 Code Mappings
CMS proposes several technical revisions to the code mappings used to classify patients under the PDPM to improve payment and coding accuracy. CMS implemented the PDPM in FY 2020 which is a new case-mix classification system to classify SNF patients under the SNF PPS. The Proposed Rule includes a request for information (RFI) on potential updates to the non-therapy ancillary component of PDPM.
Nursing Home Enforcement
CMS proposes revisions to existing long-term care (LTC) enforcement regulations that would enable CMS and the States to impose civil money penalties to “better reflect amounts that are more consistent with the type of noncompliance that occurred.” As proposed, CMS would have expanded enforcement authority to “drive sustained correction of health and safety deficiencies.” CMS is inviting comments on how to use this proposed flexibility to better hold nursing homes accountable for failing to provide safe, quality care to its residents.
SNF Quality Reporting Program (QRP)
CMS proposes a number of changes to the SNF QRP, including adding four new Social Determinants of Health (SDOH) items –one item for “Living Situations,” two items for “Food,” and one item for “Utilities”–and modifying one SDOH assessment item. These proposed changes aim to address the resident’s physical health and access to care coordination with other healthcare providers, facilities, and agencies during transitions of care. Additionally, CMS proposes that SNFs included in the SNF QRP participate in the data validation process through the Minimum Data Set, a comprehensive assessment of each resident’s functional capabilities, starting in FY 2027. CMS seeks feedback with an RFI on quality measure concepts under consideration for future SNF QRP years.
The proposed rule is scheduled to be published in the Federal Register on April 3, 2024. A display copy can be found here. The CMS fact sheet is available here.
