On Monday, July 31, 2023, the Centers for Medicare and Medicaid Services (CMS) released the public inspection version of the Fiscal Year (FY) 2024 Skilled Nursing Facility (SNF) Prospective Payment System (PPS) Final Rule. The final rule is scheduled to be published to the Federal Register on 08/07/2023.
The following is a summary of key provisions, expected to be effective on 10/01/2023, unless otherwise noted:
Topic Area: FY 2024 SNF Payment Rate
Key Points in the Proposed Rule:
- The rule finalizes the FY 2024 payment rate as a 4.0% increase for SNF PPS, which is based on a 3.0% SNF market basket increase, a 3.6% market basket forecast
error adjustment, and a -0.2% productivity adjustment, as well as a -2.3% rate adjustment attributable to the second phase of the Patient Driven Payment Model
(PDPM) parity adjustment recalibration. (Note: This rate increase is slightly higher than the proposed 3.7% increase.)
Topic Area: Updates to Urban and Rural Base Rates for the Components of theSNF Payment Driven PaymentModel (PDPM)
Key Points in the Proposed Rule:
- Tables 3 and 4 in the Final Rule reflect the updated unadjusted federal rates for FY 2024, prior to adjustment for case-mix:
Topic Area: FY 2024 SNF Wage Index
Key Points in the Proposed Rule:
- CMS continues use of the hospital inpatient wage data, exclusive of the occupational mix adjustments, in developing the SNF wage index. For the one urban area (CBSA 25980, Hinesville-Fort Stewart, GA) without wage index data, CMS continues to use the average wage indexes of all urban areas within the State.
- The wage index information applicable to FY 2024 is provided in Tables A and B in a zip file that may be accessed on the CMS website at: http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/SNFPPS/Wag eIndex.html.
- Table 7 in the Final Rule shows the update of the labor-related share from 70.8 in FY 2023 to 71.1 in FY 202.
Topic Area: PDPM ICD-10 Coding Updates
Key Points in the Proposed Rule:
- Several updates to PDPM ICD-10 Code mappings were finalized to improve consistency between code mappings and current ICD-10 coding guidelines. Links to ICD-10 code mappings zip files can be found in the PDPM Resources section on the CMS PDPM Webpage.
Topic Area: SNF Quality Reporting Program (SNF QRP)Updates
Key Points in the Proposed Rule:
CMS is making the following changes to the SNF QRP. (Note: CMS did not adopt the proposed CoreQ: Short Stay Discharge (CoreQ: SS DC) measure.)
Beginning with the FY 2025 SNF QRP:
- Modification of the COVID-19 Vaccination Coverage among HealthcarePersonnel (HCP COVID-19 Vaccine) measure.
- The current measure requires SNFs to report whether healthcare personnel(HCP) received the primary vaccination series for COVID-19. The modification will
require SNFs to report the cumulative number of HCP who are up to date with recommended COVID-19 vaccinations in accordance with the CDC’s most recent
guidance.
- Adoption of a Discharge Function Score (DC Function) measure
- Removal of the Application of Percent of Long-Term Care Hospital (LTCH) Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (Application of Functional Assessment/Care Plan) measure
- Removal of the Application of the IRF Functional Outcome Measure: Change in Self-Care Score for Medical Rehabilitation Patients (Change in Self-Care Score) measure
- Removal of the Application of IRF Functional Outcome Measure: Change in Mobility Score for Medical Rehabilitation Patients (Change in Mobility Score) measure
Beginning with the FY 2026 SNF QRP :
- Adoption of the COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date (Patient/Resident COVID-19 Vaccine) measure
- Increased SNF QRP Data Completion thresholds for the Minimum Data Set (MDS) Data Items.
- SNFs will be required to report 100% of the required quality measure data and standardized resident assessment data collected using the MDS on at
least 90% of the assessments they submit to CMS beginning in CY 2024. Noncompliance would result in a 2% reduction to the applicable fiscal year
annual payment update beginning with FY 2026 SNF QRP.
Beginning with the October 2025 Care Compare refresh or as soon as technically feasible, CMS will begin the public reporting of Post-Acute Care (PAC) measures:
- Transfer of Health Information to the Provider—PAC Measure
- Transfer of Health Information to the Patient—PAC Measure
- Data collection will begin on these measures with patients discharged on or after October 1, 2023.
Topic Area: SNF Value-Based Purchasing (SNF VBP) Program
Key Points in the Proposed Rule:
CMS is making the following changes to the SNF VBP Program. (Note: The performance year, i.e., data-collection year, is standardly year two years prior to the program year.)
Beginning with the FY 2026 program year:
- Adoption of a Nursing Staff Turnover Measure (Note: In the Comment and Response section for this topic, it is noted that “there are ongoing efforts at CMS to address staffing, including discussions around nurse staffing minimum standards.”)
Beginning with the FY 2027 program year:
- Adoption of a Discharge Function Score Measure
- Adoption of a Long Stay Hospitalization Measure per 1,000 Resident Days measure
- Adoption of a Percent of Residents Experiencing One or More Falls with Major Injury (Long Stay) measure
- Adoption of a Health Equity Adjustment for SNFs that perform well and whose resident population during the applicable performance period include at least
20% of residents with dual eligibility status - Adoption of the audit portion of the validation process for MDS-based measures
- Increase in the payback percentage from 60% to an estimated 66%, with the intention of the bonuses provided to the high-performing, high duals SNFs not coming at the expense of the other SNFs
Beginning with the FY 2028 program year:
- Replacement of the Skilled Nursing Facility 30-Day All-Cause Readmission Measure (SNFRM) with the Skilled Nursing Facility Within Stay Potentially Preventable Readmissions (SNF WS PPR) measure
Topic Area: Civil Monetary Penalties (CMP)
Key Points in the Proposed Rule:
CMS affirmed the plan to streamline the current express written waiver process to one that seamlessly flows to a constructive waiver that considers a facility to have
waived its hearing when CMS does not receive a hearing request within the requisite timeframe. The accompanying penalty reduction (which is currently set at 35%) would remain unchanged.
Topic Area: SNF Consolidated Billing (CB) Update
Key Points in the Proposed Rule:
Effective 01/01/2024, as mandated by the Consolidated Appropriations Act of 2023, marriage and family therapist (MFT) services and mental health counselor services
will be excluded from SNF CB, thus allowing separate billing by the performing clinician rather than being included in the Medicare Part A SNF payment.
Topic Area: Health Information Exchange
Key Points in the Proposed Rule:
CMS provides updates on continued efforts to promote advancement of health information exchange and encourages providers to learn more about these efforts and how they are likely to affect SNFs.
Additional Resources:
- Federal Register webpage for the final rule: Medicare Program: Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program for Federal Fiscal Year 2024
- CMS FY 2024 SNF Final Rule Fact Sheet
If you have questions or need additional information, please contact the Powerback Rehabilitation and Powerback Respiratory email inquiry system at askregulatory@powerbackrehab.com.
