CMS Releases FY 2019 Proposed Rule

Background
On Friday April 27th, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule for the Prospective Payment System & Consolidated Billing for Skilled Nursing Facilities (SNF-PPS) for FY 2019, SNF Value-Based Purchasing Program, and SNF Quality Reporting Program. The proposed rule contains information on payment updates, requirements of the SNF-VBP and SNF-QRP programs, and a new payment model for SNF’s called the Patient Driven Payment Model (PDPM).
What You Need To Know
SNF Payment Update
  • There will be a 2.4% payment update to the SNF market basket, resulting in an estimated increase of $850 million in SNF payments for FY 2019
Patient Driven Payment Model
  • CMS is proposing a new payment model called the Patient Driven Payment Model (PDPM) which would replace the current RUG-based payment model effective 10/1/2019
  • The PDPM builds upon the concepts of RCS-I by using resident characteristics as the basis for case-mix index (CMI) and payment
  • A few of the key concepts under PDPM include:
    • Each therapy discipline (PT, OT, and ST) would have their own CMI and associated payment
    • Nursing categories would be reduced from 43 to 25 by reallocating the way ADL’s are classified
    • Non-therapy ancillaries (NTA’s) would have their own CMI and associated payment
      • The IPA is a new required assessment being proposed as a means to reclassify a patient under the PDPM if certain criteria are met
  • A Variable Per Diem Adjustment would impact the PT, OT and NTA payments
  • Functional and ADL scores would be based on Section GG data rather than Section G
SNF-VBP and SNF-QRP
  • The rule contains proposals on baseline periods, reporting periods and requirements specific to each of these programs
  • Based on the FY 2018 Final Rule, the 2% recoupment with incentive payment based on rehospitalization performance for the SNF-VBP takes effect 10/1/19
  • Based on the FY 2018 final Rule, additional reporting requirements for the SNF-QRP specific to Section GG take effect 10/1/19
Although the PDPM is not scheduled to take effect until 10/1/2019, the next 2 months are a critical time as all comments related to PDPM are due to CMS by June 26th. We fully expect PDPM to become finalized with the release of the FY 2019 Final Rule in July.
PTS will be participating in the upcoming SNF Open Door Forum call covering the proposed rule on May 1st.
We will also be participating with a trade group collaborative to fully analyze the proposed rule and PDPM in preparation for our submission of comments to CMS.
PTS is developing educational materials and hosting a webinar covering all of the details of the FY 2019 Proposed Rule in the coming weeks.
PTS will continue to monitor for updates and keep our valued partners informed.

If you have any questions, please contact Matt Nash, Vice President of Strategic Development:  mnash@preftherapy.com