CMS Releases Multiple Proposed Rules

On 4/27/17, the Centers for Medicare and Medicaid (CMS) released a proposed rule and an advance notice of proposed rulemaking for the SNF setting:

  • Medicare Program: Prospective Payment System & Consolidated Billing for Skilled Nursing Facilities (SNF PPS) for FY 2018
  • Medicare Program: Prospective Payment System & Consolidated Billing for Skilled Nursing Facilities: Revisions to Case-mix Methodology (Advance Notice of Proposed Rulemaking)

What is in the SNF PPS Proposed Rule? 

  • The SNF PPS payment update is 1% for FY2018, which is an increase in payments of $390 million in FY2018
  • There are several changes to the quality measures required by the IMPACT Act.
  • Revises SNF Quality Reporting Program (SNF QRP)
  • SNF Value-Based Purchasing Program for FY 2019: proposals related to implementation of the program
  • Clarifies the regulatory requirements for team composition for surveys conducted investigating a complaint
    • Clarifies that “interdisciplinary team must include a registered nurse” is applicable to certain surveys, but not to those surveys conducted to investigate complaints or to monitor compliance on-site
  • Performance period for the National Healthcare Safety Network (NHSN) Healthcare Personnel (HCP) Influenza Vaccination Reporting Measure in the ESRD Quality Incentive Program For Payment Year
  • Soliciting comments on:
    • Potential changes to recently finalized Requirements for Long-Term
    Care Facilities that would result in a burden reduction if modified or eliminated
    • Potential CMMI models or other demonstration projects that would reduce cost and increase quality of care for SNF, or more generally
    Post- Acute Care patients
    • CMS flexibilities and efficiencies

What is the SNF Revisions to the Case-mix Methodology?
CMS is proposing to replace the current RUG case-mix system with a new one based on their payment research called the Resident Classification System. CMS intends to propose these case-mix refinements in next year’s SNF PPS Proposed Rule (for FY2019).  CMS is using this Advance Notice of Proposed Rulemaking to solicit comments on potential revisions. CMS asks for comments on many aspects of the model including complementary policies, lead time needed for software developers, etc. CMS includes a discussion of individual versus group and concurrent therapy and wants to place limits on the percent of time patients can be in group or concurrent therapy.

Preferred Therapy Solutions is currently reviewing the proposed rule to determine the impact it will have on our valued partners. As in years past, PTS will continue to work with industry leaders and advocates to provide feedback to CMS on the proposed rule. In addition, PTS will be analyzing the “Revisions to Case-Mix Methodology” advanced notice of proposed rulemaking. Although it will not impact our industry this upcoming fiscal year, the proposed revisions to SNF case-mix are significant and PTS wants to take advantage of the additional time afforded by CMS to review and comment.

Courtesy of NASL

As your Rehabilitation Partner, Preferred Therapy Solutions continues to collaborate with your facility.
If you have any questions, please contact Maria Maggi, PT / Vice President of Compliance