Medicare Skilled Nursing Facility Proposed Rule for 2020
By Scott Manson, Partner, Advisory Services
On April 25, 2019, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule for Skilled Nursing Facilities (SNF) for federal fiscal year 2020. The proposed rule includes payment updates, Patient Driven Payment Model (PDPM) implementation issues, and other items for the federal fiscal year beginning October 1, 2019. CMS is soliciting comments on the proposed rule through June 18, 2019.
The proposed rule provides for a payment increase of 2.5%. The increase is the result of a 3.0% increase in the market basket combined with a 0.5% decrease from the multifactor productivity adjustment. CMS estimates an increase of $887 million in aggregate payments to SNFs during FY 2020. However, CMS also estimates a concurrent $213.6 million decrease in aggregate payments to SNFs during FY 2020 as a result of the SNF Value Base Purchasing Program (VBP). It should be noted that these are not final amounts, and CMS states that if more recent data become available, there can be an adjustment in the final rule.
The proposed rule reports the unadjusted federal rate per diem amounts for the six new payment categories used in the PDPM. The proposed rule also updates the case-mix indices from the indices presented in the federal fiscal year 2019 final rule for the five categories which are case-mix adjusted.
The proposed rule contains several items in a section relating to PDPM implementation. CMS is proposing to define group therapy in the SNF Part A setting as a qualified rehabilitation therapist, or therapy assistant, treating two to six patients at the same time who are performing the same or similar activities. CMS also proposes to report the complete list of International Classification of Diseases Tenth Revision (ICD-10) codes associated with the SNF PDPM clinical categories and Speech Language Pathology, and Non-Therapy Ancillary comorbidities in the SNF Grouper documentation. All changes would be included in the documentation with substantive changes being included only after being finalized through notice and comment rule-making. Since PDPM requires only one 5-day MDS assessment with three grace days to be submitted no later than the eighth day of post-hospital SNF care for rate setting, CMS is proposing to refer to this simply as the initial assessment.
Quality Reporting Program (QRP)
CMS is proposing two new measures beginning with the FY 2022 SNF QRP, relating to the transfer of health information. The first item would measure the proportion of resident stays with a discharge assessment indicating that a current reconciled medication list was provided to the subsequent provider at the time of discharge. The second item would measure the proportion of resident stays with a discharge providing a current reconciled medication list to patient, family or caregiver when the patient was discharged home. The proposed rule contains more specifics on these two proposed measures and other proposed changes to the information gathering under QRP.
For those hoping for a delay in the implementation of PDPM, there is nothing in the proposed rule to indicate such. In the proposed rule, all rate information is presented in terms of PDPM, and legacy SNF PPS rate information is not even presented for comparison. The clarifications on group therapy and initial assessments can be viewed as refinements in preparation for PDPM implementation. SNFs will need to continue aggressively with their PDPM preparation and transition plans.