2022 Skilled Nursing Facility Prospective Payment System Proposed Rule

2022 Skilled Nursing Facility Prospective Payment System Proposed Rule

2022 Skilled Nursing Facility Prospective Payment System Proposed Rule Overview

On April 8, 2021, CMS issued a proposed rule that would update Medicare payment policies and rates for skilled nursing facilities under PPS for fiscal year (FY) 2022. In addition, the proposed rule includes proposals for the SNF Quality Reporting Program (QRP), and the SNF Value-Based Program (VBP) for FY 2022.

FY 2022 Proposed Updates to the SNF Payment Rates

On 10/1/21, the rates for Part A have a proposed increase of 1.3%, which equates to approximately $444 million more in payments to SNFs. These are the unadjusted rates that when multiplied by the case mix index values, determine each PDPM Case Mix Group rate.

Methodology for Recalibrating the PDPM Parity Adjustment

When finalizing PDPM, CMS stated that this new payment model would be implemented in a budget neutral manner.. Since PDPM implementation, currently available data suggest an unintended increase in payments of approximately 5 percent, or $1.7 billion in FY 2020. As with past payment model transitions, CMS has conducted the data analysis to recalibrate the parity adjustment used to achieve budget neutrality under PDPM. However, CMS also acknowledges that the COVID-19 PHE could have affected the data used to perform these analyses.

New Blood Clotting Factor Exclusion from SNF Consolidated Billing

The proposed rule includes establishing an additional category of excluded codes, specific to certain blood clotting factors and services for the treatment of hemophilia and other bleeding disorders, from consolidated billing requirements. This exclusion affects the Part A rates as the money from Part A to Part B, and as such, proposed adjustments to the Part A rates from the NTA and Nursing Components of PDPM are included.

Proposed changes in PDPM ICD-10 Code Mappings

PDPM utilizesICD-10 codes to assignpatients to clinical categories used for categorization under several PDPM components, specifically the PT, OT, SLP and NTA components. CMS is proposing several changes to the PDPM ICD-10 code mappings affecting the areas of sickle-cell disease, esophageal conditions, multisystem inflammatory syndrome, neonatal cerebral infarction, vaping-related disorder, and anoxic brain damage.

Skilled Nursing Facility Quality Reporting Program (SNF QRP) update

The SNF QRP is a pay-for-reporting program where SNFs who do not meet reporting requirements may be subject to a two-percentage point (2%) reduction in their annual update. CMS is proposing to adopt two new measures and update the specifications for another measure.

Skilled Nursing Facility (SNF) Healthcare-Associated Infections (HAI) Requiring Hospitalization Measure

The proposed measure uses claims data to estimate the rate of HAIs acquired during SNF care and result in hospitalization.  Some of the HAIs identified in this measure include sepsis, urinary tract infection, and pneumonia. The goal of the measure is to be able to assess and compare SNFs that have notably higher rates of HAIs acquired during SNF care and result in hospitalization. Implementation of the SNF HAI measure provides information about a facility’s adeptness in infection prevention and management and encourages improved quality of care.

COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure

This measure would require SNFs to report on COVID-19 HCP vaccination in order to assess whether SNFs are taking steps to limit the spread of COVID-19.. Under this proposal, SNFs would report the vaccination data through the Centers for Disease Control and Prevention National Healthcare Safety Network beginning October 1, 2021.

Skilled Nursing Facility Value-Based Purchasing (SNF VBP) Program

Proposal to suppress the SNF readmission measure in the SNF VBP Program

CMS is proposing to suppress the SNF 30-Day All-Cause Readmission Measure for the FY 2022 SNF VBP Program Year due to the significant effects of COVID-10 on the measure.

  • Under this proposed suppression policy, for all SNFs participating in the FY 2022 SNF VBP program, CMS would use the previously finalized performance period and baseline period to calculate each SNF’s risk-standardized readmission rate for the SNFRM, followed by assigning all SNFs a performance score of zero, resulting in identical performance scores and identical incentive payment multipliers.
  • CMS would provide each SNF with its SNF readmission measure rate in confidential feedback reports so that the SNF is aware of the observed changes to its measure rates, and rates would be publicly reported with appropriate caveats noting the limitations of the data due to the PHE.
  • CMS also outlines consideration for additional VBP measures, including: functional status, patient safety, and care coordination, as well as including measures expanded to all residents, not only Part A, and is requesting public comment.

HERE is a link to the CMS Fact Sheet.