Health Law Daily SNF final rule continues push to reward quality care
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Wednesday, July 31, 2019

SNF final rule continues push to reward quality care

By Kayla R. Bryant, J.D.

The rule sets rates for the new patient driven payment model case mix classification system for SNF patients.

The advance release of the skilled nursing facility (SNF) prospective payment system (PPS) final rule reveals a net 2.4 percentage point payment increase for fiscal year (FY) 2020, leading to a projected increase of $851 million in payments to SNFs next year. The rule also contains updates to the value-based purchasing (VBP) system and quality reporting program (QRP), furthering CMS’ efforts to reward value over volume, improve health information interoperability, and increase transparency to facilitate patient choice. The final rue will publish in the Federal Register August 7, 2019.

Payments. Based on the most recent data, the revised SNF market basket growth rate for FY 2020 is 2.8 percent, reduced from the proposed rule’s estimate of 3.0 percent. As required by section 3401(b) of the Patient Protection and Affordable Care Act (ACA) (P.L. 111-148), the SNF market basket percentage is reduced annually by the multifactor productivity (MFP) adjustment. The MFP adjustment was estimated in the proposed rule to be 0.5 percent but has been reduced by more recent data to 0.4 percent. This adjustment results in a 2.4 percent SNF market basket update for FY 2020.

Patient driven payment model. The newly-created patient driven payment model (PDPM), finalized last year, creates a new case-mix classification system for SNF patients (see CMS changes SNF case mix, finalizes PDPM, predicts $820M payment increase, August 1, 2018). The unadjusted federal per diem rates under PDPM are divided into six components: physical therapy (PT); occupational therapy (OT); speech-language pathology (SLP); nursing; non-therapy ancillaries (NTA); and one non-case-mix component. This new case-mix model is designed to remove an incentive to provide a high volume of therapy regardless of need, and instead takes into account patient characteristics classify them into payment groups. For FY 2020, the urban rates are:

  • PT: $60.75;
  • OT: $56.55;
  • SLP: $22.68;
  • Nursing: $105.92;
  • NTA: $79.91;
  • Non-case-mix: $94.84.

Rural rates are:

  • PT: $69.25;
  • OT: $63.60;
  • SLP: $28.57;
  • Nursing: $101.20;
  • NTA: 76.34;
  • Non-case-mix: $96.59.

The rates are subject to various adjustments contained in the rule.

Quality reporting program. SNFs failing to submit required data under the QRP are subject to a 2 percentage point reduction to the annual market basket percentage update. Beginning in FY 2022, the SNF QRP will include two new quality measures that address the transfer of patient information to prevent information blocking, promote care coordination, and improve interoperability. The Transfer of Health Information to the Provider—Post-Acute Care (PAC) measure addresses the provision of a current reconciled medication list to the appropriate provider after a patient leaves a PAC setting. The Transfer of Health Information to the Patient—PAC measure addresses the provision of a medication list to the patient, family, or caregiver when a patient leaves a PAC setting for a private residence or other home living arrangement, including when under the care of home health services or hospice.

MainStory: TopStory NewsStory ReimbursementNews CMSNews PartBNews QualityNews SNFNews

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