LeadingAge NY Comments on SNF PDPM Proposal
LeadingAge NY submitted detailed written comments to the Centers for Medicare and Medicaid Services (CMS) on the Skilled Nursing Facility Prospective Payment System (SNF PPS) Rule. This Rule includes the proposal to implement a new case-mix classification system as the basis for SNF Medicare Part A payments effective Oct. 1, 2019. CMS had received approximately 300 comments on the proposal as of June 27th, the day after the deadline.
The Patient-Driven Payment Model (PDPM) would base payment not on the amount of services provided, but on resident characteristics that are predictive of service needs. While a focus on more accurately reimbursing for the cost of care as well as impact estimates provided by CMS suggest that many not-for-profit providers would see a potential increase in revenue under the change, the change could significantly negatively impact some LeadingAge NY members.
Our comments raise concerns about the veracity of the data used to make decisions about various features of the system and model the potential impacts; the new expectations around resident assessments; impacts on certain facilities and payment levels for specialty populations; how PDPM could affect other federal and state initiatives; and the considerable costs and time investments that SNFs and other stakeholders will incur to transition to the new system. We are grateful to the LeadingAge NY members that shared their input with us.
LeadingAge NY’s memo outlining the proposed methodology is available here.
Contact: Dan Heim, dheim@leadingageny.org, 518-867-8866