CMS Releases FY 2022 SNF Final Rule
On July 29, 2021, the Centers for Medicare and Medicaid Services (CMS) posted the public inspection version of a final rule titled, 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 2022; and Technical Correction to Long-Term Care Facilities Physical Environment Requirements. This rule confirms the following final updates and actions for FY 2022 (effective date October 1, 2021), as well as some future updates:
- A 1.2% increase in payment rates for the Skilled Nursing Facility (SNF) Prospective Payment System (PPS), which is a decrease of 0.1% from the proposed increase
- No Patient-Driven Payment Model (PDPM) Parity Adjustment in FY 2022
- CMS acknowledged provider concerns and recommendations regarding a methodology for recalibration of the parity adjustment to account for unintended increases in payments. CMS plans to continue to evaluate the feedback received and address the parity adjustment issue further in the FY 2023 SNF PPS Proposed Rule.
- Updates to urban and rural base rates for the components of SNF PDPM with $.01 to .04 decreases in the unadjusted federal rate per diem. (Final Rule section IV(B)(6))
- Table 4: FY 2022 Unadjusted Federal Rate Per Diem – URBAN
- Table 5: FY 2022 Unadjusted Federal Rate Per Diem – RURAL
- Update to PPS payment rates using a 2018-based SNF market basket rather than the 2014-based SNF market basket
- Updates to the SNF PPS wage index and geographic delineations, with a 1-year transition policy for SNFs affected by changes in the Office of Management and Budget (OMB) designation of urban and rural areas
- Changes to PDPM ICD-10 code mappings affecting the areas of sickle-cell disease, esophageal conditions, multisystem inflammatory syndrome, neonatal cerebral infarction, vaping-related disorders, and anoxic brain damage
- SNF Quality Reporting Program (QRP) updates, including:
- Addition of two new measures, a Skilled Nursing Facility (SNF) Healthcare-Associated
- Infections (HAI) Requiring Hospitalization Measure and a COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure, beginning with the FY 2023 SNF QRP
- Updated specifications for the Transfer of Health Information to the Patient - PAC Quality Measure, removing patients discharged to home under the care of a home health organization from the definition of the denominator for this measure, beginning with the
- FY 2023 SNF QRP
- Finalized plan to use the COVID-19 Affected Reporting (CAR) scenario to publicly report SNF QRP measures for the January 2022 through July 2023 data refreshes (Details and related tables can be found in Section VII(C) of the final rule.)
- CMS notes that “the CAR scenario uses the most recently available data to simulate the public health emergency reality where quarters 1 and 2 of a calendar year must be excluded from calculation.” For example, CMS calculated SNF QRP measures using 3 quarters (Q2 2019 through Q4 2019) of SNF QRP data for assessment-based measures, and 6 quarters (Q1 2018 through Q4 2018 and Q3 2019 through Q4 2019) for claims-based measures.
- SNF Value-Based Purchasing (VBP) Program updates (Final Rule Section VIII), including:
- Suppression of the Skilled Nursing Facility 30-Day All-Cause Readmission Measure (SNFRM) for the FY 2022 SNF VBP Program Year due to circumstances caused by the Public Health Emergency (PHE) for COVID-19 and its impact, in order to make fair, national comparisons of SNF performance scores
- Finalized the revised Performance Period for the FY 2022 SNF VBP Program as April 1, 2019 through December 31, 2019 and July 1, 2020 through September 30, 2020
- Adoption of a 90-day SNFRM risk-adjustment lookback period for the FY 2023 SNF VBP Program performance period
- Finalized plan to use FY 2019 data for the FY 2024 baseline period
- Summary of feedback received regarding future plans to expand the SNF VBP program and apply additional measures of functional status, care coordination, patient safety, or patient experience, with CMS acknowledgement of plan to consider the feedback as future VBP policies are developed and also acknowledgement of plans to report SNF employee turnover information in the near future
Additionally, the final rule includes the following:
- Acknowledgment of comments obtained through The Closing the Health Equity Gap Request for Information (RFI)
- Acknowledgement of comments obtained through the Fast Healthcare Interoperability Resources (FHIR) in Support of Digital Quality Measurement in Post-Acute Care Quality Reporting Programs – RFI
- Ongoing initiatives to advance interoperable health information technology and exchange
- FY 2022 SNF PPS Federal Wage Index zipfile
Additional Resources:
- Federal Register page for FY 2022 SNF Final Rule (rule was published to the Federal Register on 08/04/2021)
- SNF Final Rule Fact Sheet
- SNF QRP COVID-19 Public Reporting Tip Sheet
- FY 2022 SNF PPS Federal Wage Index zipfile
If you have questions or need additional information, please contact the Genesis Rehab Services (GRS)/Respiratory Health Services (RHS) email inquiry system at GRSASK@genesishcc.com.
