Picture: FG Commerce/Getty Photos
The Facilities for Medicare and Medicaid Companies have issued a proposed rule that might replace Medicare fee insurance policies and charges for expert nursing services underneath the Potential Expert Nursing Facility Cost System for fiscal 12 months 2024.
It additionally consists of proposals for the SNF High quality Reporting (QRP) program and the SNF Worth-Primarily based Buying (VBP) program for FY 2024 and past.
The proposed rule would additionally take away the requirement for services to actively waive their proper to a listening to in writing and as an alternative deal with failure to submit a well timed request to be heard as a constructive waiver.
The administration has framed the proposed rule as half of a bigger effort to enhance the security and high quality of care in nursing properties. CMS mentioned it was nonetheless dedicated to proposing minimal staffing requirements for nursing services by the spring.
PROPOSED UPDATES TO SNF PAYMENT RATES
CMS estimates that the combination impression of the fee insurance policies within the proposed rule would end in a internet enhance of three.7%, or roughly $1.2 billion, in Medicare Half A funds to NFCs in fiscal 2024.
In 2019, CMS carried out a brand new case-mix classification system, the PDPM, in an ostensibly budget-neutral method, intending that the transition to PDPM from the earlier case-mix classification mannequin, the Useful resource Utilization Group, Model 4 (RUG -IV), wouldn’t result in a rise or lower in combination NFC spending. However because the implementation of the PDPM in fiscal 2020, preliminary evaluation of CMS information confirmed an unintended enhance in funds of about 5%, or $1.7 billion yearly.
After contemplating the stakeholder suggestions obtained on the proposed SNF FY 2023 PPS rule, CMS finalized a 4.6% PDPM parity adjustment issue within the last rule with a two-year phase-in interval, leading to a discount of two .3% in FY 2023 and a 2.3% discount in FY 2024 to PPS SNF fee charges.
PROPOSED CHANGES TO SNF QRP
CMS proposes the adoption of the measure of the Discharge Perform Rating (DC Perform) ranging from FY 2025 SNF QRP. This measure assesses purposeful standing by assessing the proportion of SNF residents who meet or exceed a predicted discharge operate rating and makes use of the mobility and self-care parts already collected within the minimal information set (MDS).
The adoption of the CoreQ: Quick Keep Discharge (CoreQ: SS DC) measure can be proposed ranging from FY 2026 SNF QRP. This measure calculates the proportion of people discharged from an NFS, inside 100 days of admission, who’re glad with their NFS keep. The questionnaire that might be administered as a part of the CoreQ measure: SS DC asks individuals to price their total satisfaction with their care utilizing a five-point Likert scale. Areas of help embody employees, the help obtained, recommending the power to family and friends, and the way their discharge wants have been met.
CMS additionally proposes the adoption of the measure COVID-19 Vaccine: P.c of Sufferers/Residents As much as Date (Affected person/Resident COVID-19 Vaccine) ranging from FY 2026 SNF QRP. This measure studies the proportion of stays by which SNF residents are updated with really useful COVID-19 vaccinations in accordance with the newest tips from the Facilities for Illness Management and Prevention. The info could be collected utilizing a brand new ingredient standardized on the MDS.
One other proposal is to change the measure referring to COVID-19 vaccination protection amongst healthcare personnel (HCP COVID-19 Vaccine) ranging from FY 2025 SNF QRP. This measure tracks the proportion of healthcare personnel (HCPs) working in SNF who’re thought-about updated with the really useful COVID-19 vaccination in accordance with the newest CDC tips.
CMS Proposes to Take away the Measure of Enforcement of Inpatient Lengthy Time period Care (LTCH) Inpatient Charge with an Admission and Discharge Purposeful Evaluation and a Care Plan That Addresses the Perform (Enforcement of Purposeful Evaluation/Care Plan) ; the appliance of purposeful consequence measures of the IRF: change in self-care rating for sufferers in medical rehabilitation (change in self-care rating); and Mobility Rating Change for Medical Rehabilitation Sufferers (Mobility Rating Change) as of FY 2025 SNF QRP.
The company can be evaluating the opportunity of growing the SNF QRP information completion thresholds for Minimal Information Set (MDS) information objects starting in FY 2026 SNF QRP. CMS proposes that NFCs ought to report 100% of the required high quality measurement information and standardized resident evaluation information collected utilizing the MDS on at the very least 90% of the assessments they undergo CMS. Any NFS that fails to satisfy the proposed requirement that 90% of all submitted MDS assessments include 100% of the required information can be topic to a 2 proportion level discount from the relevant tax 12 months’s annual fee replace ranging from fiscal 12 months 2026.
PROPOSED CHANGES TO THE VBP SNF PROGRAM
The SNF Expert Nursing Facility Worth-Primarily based Buying (VBP) program rewards NSFs with incentive funds primarily based on the standard of care they supply. All SNF paid underneath Medicare’s SNF PPS are included within the SNF VBP program.
CMS proposes adoption of the nurse turnover measure for the SNF VBP program starting with program 12 months FY 2026 and efficiency 12 months FY 2024. It is a structural measure that has been collected and publicly reported on Care Examine and consider staffing stability inside an NFC utilizing nursing employees turnover. That is a part of the administration’s said aim of guaranteeing satisfactory staffing in long-term care services. Amenities will start reporting on this measure in FY2024, with fee results beginning in FY2026.
The adoption of the Discharge Perform Rating measure can be proposed ranging from the planning 12 months FY 2027 and from the efficiency 12 months FY 2025. This measure can be proposed for NSF QRP and evaluates the purposeful standing by evaluating the proportion of NSF residents who meet or exceed an anticipated discharge operate rating and use mobility and self-care objects already collected on the MDS.
Different proposals: the adoption of the Lengthy-Time period Care Measure for 100 residents ranging from the 2027 program 12 months and from the 2025 efficiency 12 months; a adoption of the proportion of residents who are suffering a number of falls with severe harm (lengthy keep) ranging from this system 12 months FY 2027 and from the efficiency 12 months FY 2025; and Changing the 30-Day Expert Nursing Facility All-Trigger Readmission Measure (SNFRM) with the Probably Preventable Expert Nursing Facility Readmissions Throughout Keep Measure (SNF WS PPR) efficient in program 12 months FY 2028, and from efficiency 12 months FY 2025.
In an effort to prioritize reaching well being fairness and decreasing disparities in well being outcomes in NFCs, CMS proposes the adoption of a well being fairness adjustment within the SNF VBP program which rewards NFCs who carry out effectively and whose inhabitants resident throughout the relevant profit interval consists of at the very least 20% of residents with twin eligibility standing. This adjustment would start with program 12 months FY 2027 and efficiency 12 months FY 2025. CMS is adjusting the scoring methodology to offer bonus factors to high-performing services that service the next proportion of doubles.
As well as, CMS proposes to extend the payback price coverage underneath the VBP SNF program from the present 60% to a stage such that the bonuses supplied to high-performing and high-dual NSFs don’t come on the expense of different NSFs. Estimates for the FY 2027 planning 12 months are 66%.
The proposed rule additionally offers additional updates on the validation course of being developed for standardized high quality measures and evaluation information for NFCs. CMS proposes the addition of the audit portion of the validation course of for MDS-based measures beginning with program 12 months FY 2027 and efficiency 12 months FY 2025.
Electronic mail the author: Jeff.Lagasse@himssmedia.com