Effective October 1, 2019, the Centers for Medicare & Medicaid Services (CMS) implemented a new reimbursement system for skilled nursing facilities (SNFs), called Patient-Driven Payment Model (PDPM).[1] Although CMS intended for PDPM to be budget-neutral, it noted in the April 2021 Notice of Proposed Rulemaking to update Medicare rates for Fiscal Year 2022 that, following implementation of PDPM in October 2019, physical and occupational therapy declined 30%, from 91 minutes per resident per day in FY2019 to 62 minutes per day in FY2020, and concurrent and group therapy increased to 32% and 29%, respectively.[2] CMS identified a 5.3% increase in aggregate spending with PDPM and considered reducing payments to SNFs by 5% ($1.7 billion). In the final rule, however, CMS defers recalibrating the PDPM parity adjustment until the FY2023 SNF PPS Proposed Rule.[3] CMS estimates that the final rule will increase Part A payments to SNFs by approximately $410 million in FY2022.[4]
As required by the Consolidated Appropriations Act, 2021, CMS excludes certain specified blood clotting factors from SNF consolidated billing.[5]
As proposed, beginning with FY2023 for the SNF Quality Reporting System, CMS adds two new measures: SNF Healthcare-Associated Infections Requiring Hospitalization measure (SNF HAI)[6] and the COVID-19 Vaccination Coverage among Healthcare Personnel (HCP).[7]
With respect to the SNF Value-Based Purchasing Program, CMS indicates that it will consider public comments as it develops potential future measures and reiterates its plan to report employee turnover information “in the near future.”[8]
September 2, 2021 – T. Edelman
[1] 83 Fed. Reg. 39,162, 39,183-39,265 (Aug. 8, 2018)
[2] 86 Fed. Reg. 19,954, 19,986 (Apr. 15, 2021). See “CMS Confirms Steep Decline in Therapy at Nursing Facilities” (CMA Alert, May 6, 2021), https://medicareadvocacy.org/cms-confirms-steep-decline-in-therapy-at-nursing-facilities/ (discussing proposed rule)
[3] 86 Fed. Reg. 42,424, 42,466-42,471 (Aug. 4, 2021)
[4] CMS, “Fiscal Year (FY) 2022 Skilled Nursing Facility (SNF) Prospective Payment System (PPS) Final Rule (CMS-1746-F)” (Fact Sheet, Jul. 29, 2021), https://www.cms.gov/newsroom/fact-sheets/fiscal-year-fy-2022-skilled-nursing-facility-snf-prospective-payment-system-pps-final-rule-cms-1746
[5] 42 C.F.R. §489.20(s)(17), as discussed at 86 Fed. Reg. 42,424, 42,442-42,444 (Aug. 4, 2021)
[6] 86 Fed. Reg. 42,424, 42,480 (Aug. 4, 2021)
[7] 86 Fed. Reg. 42,424, 42,489 (Aug. 4, 2021)
[8] 86 Fed. Reg. 42,424, 42,511 (Aug. 4, 2021)