The Center for Medicare Advocacy has submitted comments on the proposed annual update for Medicare reimbursement for skilled nursing facilities. The Centers for Medicare & Medicaid Services (CMS) predicted in 2018 that implementation of the new reimbursement system, the Payment Driven Payment Model (PDPM), could result in residents’ receiving less therapy. CMS’s final rule establishing PDPM included methods to monitor and correct inappropriate declines in therapy services. However, while repeatedly documenting since 2019 that residents are receiving less therapy than before, CMS has not taken any steps to correct the problem and to ensure that residents actually receive the therapy they need to improve or, as required by the nationwide class action settlement in Jimmo v. Sebelius, No. 5:11-CV-17-CR (D.Vt. Jan. 2013) (Court-approved settlement, CMS website discussing case), to maintain function and prevent or slow their decline or deterioration.
Comments are due June 1, 2026. Please feel free to use the Center’s comments, which address therapy services and other issues.
- Read CMA’s full comments at medicareadvocacy.org/wp-content/uploads/2026/05/Nursing-Homes-NPRM-SNF-Part-A-CMA-Comments-May-2026.pdf