Comments Due Wed., June 10 for New CMS Proposed Rule
The Mon., April 20 Federal Register contains a Centers for Medicare and Medicaid Services (CMS) proposed rule that would update the payment rates used under the Prospective Payment System (PPS) for Skilled Nursing Facilities (SNFs); specify a 30-day SNF all-cause, all-condition hospital readmission measure, and adopt that measure for a new SNF Value-Based Purchasing (VBP) Program; implement a new quality reporting program for SNFs; and amend requirements for participating long term care facilities to implement the Affordable Care Act (ACA) mandate for submission or payroll-based staffing data. Key features of the proposed rule are as follows:
- Based on proposed changes contained within this rule, CMS projects that aggregate payments to SNFs will increase by $500 million, or 1.4 percent, from payments in FY 2015. This estimated increase is attributable to a 2.6 percent market basket increase, reduced by a 0.6 percentage point forecast error adjustment and further reduced by 0.6 percentage point, in accordance with the multifactor productivity adjustment required by law.
- CMS would specify a 30-day SNF all-cause, all-condition hospital readmission measure, and would adopt that measure for a new SNF VBP Program;
- This measure [endorsed by the National Quality Forum (NQF) in December 2014] would assesses the risk-standardized rate of all-cause, all-condition, unplanned inpatient hospital readmissions of Medicare Fee-for-Service (FFS) SNF patients within 30 days of discharge from an inpatient prospective payment system hospital; critical access hospital; or psychiatric hospital.
- The measure is claims-based, requiring no additional data collection or submission burden for SNFs.
- The implementation of a new quality reporting program for SNFs as specified in the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act).
- The IMPACT act requires CMS to specify standard assessment tools across PAC providers (SNF, home health, IRF, LTCH) along with cross-setting quality measures by October 2015, in three domains: functional status, cognitive function and changes in cognition; skin integrity and changes in skin integrity; and incidence of major falls.
- Amending the requirements for long term care facilities to incorporate the provisions in the ACA and IMPACT Act regarding submission of payroll-based staffing data, including the category of work performed and the hours of work provided by each category per resident per day.
- CMS would amend 483.75-Administration by adding a new paragraph (u), Mandatory Submission of Staffing Information Based on Payroll Data in a Uniform Format.
- The proposed regulation would require facilities to electronically submit to CMS complete and accurate direct care staffing information, including information for agency and contract staff, based on payroll and other verifiable and auditable data, beginning July 1, 2016.
- CMS would amend 483.75-Administration by adding a new paragraph (u), Mandatory Submission of Staffing Information Based on Payroll Data in a Uniform Format.
Comments are requested no later than Wed., June 10, 2015 and may either be submitted directly to emunley@LeadingAge.org or may be submitted LeadingAge NY; comments will be submitted on behalf of members.
Contact: Elliott Frost, efrost@leadingageny.org, 518-867-8832