CMS Seeks Comments on Proposed Rule for FY2023 SNF Prospective Payments System | King and Spalding

On April 11, 2022, CMS released its Proposed Prospective Payment System (PPS) Rule for the Skilled Nursing (SNF) Facility for FY 2023, updating Medicare payment policies and rates. for NFS. The proposed rule also includes proposals for the SNF Quality Reporting Program (QRP) and the SNF Value-Based Program (VBP) for fiscal year 2023 and future years, and it invites comments on resolving staffing constraints and the turnover in nursing homes and health equity disparities. Comments should be provided to CMS by June 10, 2022. The main highlights of the proposed rule are summarized below.


The proposed rule includes an overall decrease in the SNF payment rate of approximately $320 million in fiscal year 2023 compared to fiscal year 2022, which includes an annual payment update of 3.9% and the implementation of a reduction of 4.6% to maintain budget neutrality from the implementation of the payment. – Driven Payment Model (PDPM). In addition, the proposed rule would include a permanent 5% cap on annual wage index decreases to limit year-to-year variations in FNS payments associated with changes in the index. The proposed rule also contains several changes to the ICD-10 PDPM code mappings and coding guidelines for better consistency.


The proposed rule would adopt the metric Flu Vaccine Coverage Among Healthcare Personnel to assess the percentage of healthcare personnel physically present at the facility who have received an influenza vaccine. The proposed rule would also defer the collection of two new quality measures – transfer of health information to patient and transfer of health information to provider, as well as certain standardized patient assessment data elements – to October 1. 2023.


Additional measures have been added to the SNF VBP program, including: (1) SNF’s Healthcare Associated Infections Requiring Hospitalization (HAI) measure, which is an outcome measure assessing SNF’s performance in prevention and infection management in fiscal year 2026; (2) measurement of total nursing hours per resident day in fiscal year 2026; and (3) adoption of the community discharge measure, which is an outcome measure assessing the rate of successful discharges to the community of NFCs in fiscal year 2027.


The proposed rule also invites input on several topics, including establishing the minimum staffing requirements necessary to ensure the delivery of safe, high-quality care, developing strategies to improve the measurement of disparities in health outcomes, health care and stakeholder feedback on a measure to address staff turnover. levels in nursing homes for possible inclusion in the SNF VBP program in the future.

A CMS factsheet on the proposed rule can be found here, and the full proposed rule can be found here.

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