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The Centers for Medicare and Medicaid Services has issued a proposed rule that would update Medicare payment policies and rates for skilled nursing facilities under the Skilled Nursing Facility prospective payment system for fiscal year 2022. 

The proposed rule also includes proposals for the SNF Quality Reporting Program and the SNF Value-Based Program.

According to CMS estimates, the impact of the payment policies in the proposed rule would result in an increase of about $444 million in Medicare Part A payments to SNFs in FY22. 

This estimate reflects a $445 million increase from the update to the payment rates of 1.3{f08ff3a0ad7db12f5b424ba38f473ff67b97b420df338baa81683bbacd458fca} – which is based on a 2.3{f08ff3a0ad7db12f5b424ba38f473ff67b97b420df338baa81683bbacd458fca} SNF market basket update, minus a 0.8 percentage point forecast error adjustment and a 0.2 percentage point multifactor productivity adjustment – and a $1.2 million decrease due to the proposed reduction to the rates to account for the recent blood-clotting-factors exclusion. 

That exclusion requires that certain specified blood-clotting factors used for the treatment of patients with hemophilia and other bleeding disorders be excluded from the consolidated billing requirements for items and services furnished on or after October 1.

As a result, CMS is proposing a proportional reduction in the Medicare Part A SNF rates to account for this new exclusion. If finalized, this would result in an estimated decrease of about $1.2 million in aggregate Part A SNF spending. The reduction is intended to offset the increase in Part B spending that will occur due to these items and services being excluded from SNF consolidated billing.

The total impact figures do not incorporate the SNF VBP reductions, which are estimated to be $184.25 million in FY22.

WHAT’S THE IMPACT?

The skilled nursing facility quality reporting program is a pay-for-reporting program. SNFs that do not meet reporting requirements may be subject to a 2{f08ff3a0ad7db12f5b424ba38f473ff67b97b420df338baa81683bbacd458fca} reduction in their annual update. CMS is proposing to adopt two new measures and update the specifications for another measure, and is also proposing a modification to the public reporting of SNF quality measures.

Meanwhile, the agency is proposing to suppress the SNF 30-Day All-Cause Readmission Measure because circumstances caused by the COVID-19 public health emergency have significantly affected the measure and the resulting performance scores.

Specifically, to address the possible distortion of performance scores and incentive payment multipliers, CMS is proposing to assign a performance score of zero to all participating SNFs, irrespective of how they perform using the previously finalized scoring methodology.

Per statute, the SNF VBP Program must withhold 2{f08ff3a0ad7db12f5b424ba38f473ff67b97b420df338baa81683bbacd458fca} of SNF Medicare Part A fee-for-service payment and redistribute 50-70{f08ff3a0ad7db12f5b424ba38f473ff67b97b420df338baa81683bbacd458fca} of the withhold in the form of incentive payments.

To maintain compliance with the existing payback percentage policy, CMS is proposing to reduce the otherwise applicable federal per diem rate for each SNF by 2{f08ff3a0ad7db12f5b424ba38f473ff67b97b420df338baa81683bbacd458fca} and award SNFs 60{f08ff3a0ad7db12f5b424ba38f473ff67b97b420df338baa81683bbacd458fca} of that withhold, resulting in a 1.2{f08ff3a0ad7db12f5b424ba38f473ff67b97b420df338baa81683bbacd458fca} payback percentage to those SNFs, except for SNFs that are subject to the low volume adjustment policy.

Long-term care facilities should continue to adhere to evidence-based infection control practices and CMS’ Requirements for Participation, the agency said.

THE LARGER TREND

Compliance with the requirements is critical, since nursing home residents are more susceptible to severe infection from COVID-19 due to their age, their underlying health conditions and the congregate setting, CMS said.
 

Twitter: @JELagasse
Email the writer: [email protected]



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