CMS Proposes Changes to Skilled Nursing Facility Payment System
The Centers for Medicare and Medicaid Services (CMS) is nearing the finalization of the Skilled Nursing Facility Prospective Payment System (SNF PPS) slated for July. A key focus is the significant increase in coding for certain medical conditions. This shift prompts CMS to determine whether it reflects genuine changes in resident health complexities or simply enhanced care practices, as opposed to manipulation for higher reimbursements.
Nursing home administrators are encouraged to provide detailed examples during the comment period, ending on June 3. These submissions should illustrate genuine advancements in care practices, particularly for conditions like malnutrition, depression, and swallowing disorders, under the Patient Driven Payment Model (PDPM).
CMS's proposed rule could lead to a 2.4% payment increase, equating to approximately $888 million. However, these changes hinge on CMS's evaluation of whether the coding surge justifies adjusted funding due to potential "case mix creep."
Impact of Coding Increases
Joe Price, regulatory solutions strategist at Netsmart, explained that CMS seeks explanations for increased coding within the Minimum Data Set (MDS) from skilled nursing facilities. Notably, the coding for malnutrition rose from 5% to 47%, as indicated by Tara Altenritter, director of solution management at Simple, a Netsmart product. Altenritter stressed the necessity of documenting valid improvements in patient assessment and care.
CMS is reconsidering adjustments for physical, occupational, and speech therapy payments, with a proposed 5.87% reduction for speech therapy adjustments. Altenritter noted that even small percentage changes could significantly impact revenues for operators handling medically complex demographics, emphasizing the importance of data-backed feedback during the SNF PPS comment period.
Regulatory Changes and Feedback
Furthermore, proposals aim to shorten Minimum Data Set (MDS) submission timelines from 4.5 months to 45 days and expand reporting to encompass all payer types, beyond Medicare. This shift mirrors the increased use of Medicare Advantage plans. Pat Newberry, clinical reimbursement consultant for Netsmart, stated that this change is meant to enhance workflows and provide a more comprehensive understanding of patient populations, despite initial concerns over increased workloads.
Additional considerations include plans to remove specific Covid-19 vaccine measures and update quality reporting programs. The introduction of a preventable readmission measure, replacing the all-cause readmission measure, is another upcoming change providers need to prepare for. Newberry emphasized that submitting feedback during CMS's information requests is crucial, as frontline input can significantly sway final regulations.
In conclusion, professionals in skilled nursing facilities are urged to actively participate in the regulatory feedback process, providing CMS with robust evidence of ongoing improvements in care quality and operational efficiencies. This collaborative approach is pivotal in shaping future regulations and ensuring sustainable advancements in the industry.