The Final Rule is the newest standards for Skilled Nursing facilities and are proposed usually around April (Spring) and there is a 60-day comment period for providers. CMS must update the SNF PPS payment rules annually, including unadjusted federal per diem rates to be applied to days of covered SNF services furnished during the next fiscal year; the case-mix classification system to be applied for these services during the next fiscal year; the factors to be applied in making the area wage adjustment for these services. 

Here are the Top 5 Important Items in the 2023 Proposed SNF Final Rule:

5.  Additional measures to be added to the VBP (Value Based Purchasing) Program - 
The SNF VBP Program rewards SNFs with incentive payments based on the quality of care they provide to Medicare beneficiaries, as measured by performance on a single measure of hospital readmissions. All SNFs paid under Medicare’s SNF PPS are included in the SNF VBP Program.  FY 2026 Program year: Adoption of the Skilled Nursing Facility Healthcare Associated Infections Requiring Hospitalization (SNF HAI) and Total Nursing Hours per Resident Day measures.  FY 2027 Program year: Adoption of the Discharge to Community – Post Acute Care Measure for SNFs (DTC). The DTC is an outcome measure that assesses the rate of successful discharges to community from a SNF setting.

4.  Updated 2025 SNF Quality Reporting Program (QRP) - 
The SNF QRP is a pay-for-reporting program. SNFs that do not meet reporting requirements are subject to a two-percentage point (2.0) reduction in their annual update. CMS is proposing the adoption of a new process measure, the Influenza Vaccination Coverage among Healthcare Personnel (HCP) measure for the SNF QRP, beginning with the FY 2025 SNF QRP.  Residents of long-term care facilities, who are often of older age, have greater susceptibility for acquiring influenza due to general frailty and co-morbidities, close contact with other residents, interactions with visitors, and exposure to staff who rotate between multiple facilities. CMS is also proposing to revise the compliance date for certain SNF QRP reporting requirements including the Transfer of Health Information measures and certain standardized patient assessment data elements (including race, ethnicity, preferred language, health literacy, social isolation) to October 1, 2023.

3.  Proposed remapping of ICD-10 codes to “Return to Provider” & “Medical Management” - 
PDPM utilizes International Classification of Diseases, Version 10 (ICD-10) codes in several ways, including to assign patients to clinical categories used for categorization under several PDPM components, specifically the Physical Therapy, Occupational Therapy, Speech Language Pathology and Non-Therapy Ancillary components. In response to stakeholder feedback and to improve consistency between the ICD-10 code mappings and current ICD-10 coding guidelines, CMS is proposing several changes to the PDPM ICD-10 code mappings. See more details here.

2.  Request for Information regarding Infection Isolation - 
CMS is seeking input on the effect of direct care staffing requirements to improve the long-term care requirements for participation and promote thoughtful, informed staffing plans and decisions within facilities to meet residents’ needs, including maintaining or improving resident function and quality of life.  After the COVID-19 pandemic and the increase cost and inability to capture residents in isolation on the Minimum Data Set MDS due to cohorting, stakeholders requested changes of the criteria to code infection isolation. As a result, CMS is seeking comments on the extent to which the existing criteria should be expanded.

1.  Recalibrating of the PDPM Parity Adjustment - 
The proposed rule decreases payments under Medicare Part A to SNFs by about $320 million for FY 2023. CMS says the decrease reflects a $1.4 billion increase due to the 3.9% payment rate update, based on the SNF market basket update of 2.8%. The payment rate update reflects a 1.5 percentage point increase for market basket forecast error adjustment and a 0.4 percentage decrease for productivity adjustment. The $320 million reduction reflects a $1.7 billion, or 4.6%, decrease in the SNF PPS rates due to the proposed recalibrated parity adjustment.
The proposed rule also includes several Request For Information (RFI) on payment, policies, and additional proposed measures. Please see the CMS Fact Sheet. 
See more details here.

Questions or concerns?  Feel free to send JMD Healthcare questions concerning therapy documentation or treatments to receive a FREE risk analysis with referenced Medicare Guidelines to help maintain compliance in your facility. 
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