LeadingAge NY Comments on SNF PPS Proposed Rule

Last week, LeadingAge NY submitted detailed written comments to the Centers for Medicare and Medicaid Services (CMS) on the Skilled Nursing Facility (SNF) Prospective Payment System (PPS) Proposed Rule for Fiscal Year (FY) 2021. The rule calls for a 2.3 percent market basket increase, which would boost total SNF payments nationally by $784 million in FY 2021 relative to FY 2020. The rule does not propose any significant changes to the Patient-Driven Payment Model (PDPM).

In response to stakeholder recommendations, the proposed rule includes several changes to the ICD-10 code mappings that would be effective beginning in FY 2021. The rule also proposes Value-Based Purchasing (VBP) performance periods and performance standards for upcoming program years and would apply the 30-day Phase One Review and Correction deadline to the baseline period quality measure quarterly report. CMS is not proposing to make any changes to the measures, SNF VBP scoring policies, or payment policies.

Finally, the proposal would revise geographic delineations that impact wage index region assignments for certain counties but would also apply a cap to ensure that no impacted region would experience a wage index decrease of more than 5 percent as a result of the change. The three counties potentially impacted in New York State are Dutchess, Orange, and Putnam.

The CMS fact sheet is available here, and the published proposed rule is posted in the Federal Register. LeadingAge NY’s comments on the proposal focused on the financial and operational implications of the COVID-19 pandemic and how these should be addressed in PPS payments and the SNF quality programs.

Contact: Dan Heim, dheim@leadingageny.org