The Centers for Medicare & Medicaid Services (CMS) publicly posted the pre-published fiscal year (FY) 2020 Skilled Nursing Facility Prospective Payment System (SNF PPS) Final Rule. The rule includes updates to the Medicare Part A unadjusted federal per-diem payment rates. And CMS is projecting aggerate payments to SNFs will increase by 2.4%, or $851 million, in FY2020 vs. FY2019. This is due to a 2.8% market basket increase with a 0.4 percentage point reduction to account for the multifactor productivity adjustment. Other key adoptions:

 

The Patient-Driven Payment Model (PDPM)

    • Assessment Terminology Change. CMS is replacing the term “5-day assessment” with “Initial Medicare Assessment”.
    • Sub-regulatory Process for Updating ICD-10-CM Codes. Since PDPM uses ICD-10-CM codes to determine payment group classification, CMS adopted a sub-regulatory process for non-substantive updates to ICD-10-CM codes used for PDPM clinical classification. This ensures the most current ICD-10-CM codes are available to providers and aligns with the Inpatient Rehabilitation Facility (IRF) PPS. Substantive changes will continue to follow the normal rulemaking process.
    • Patient Health Questionnaire-2 to 9 (PHQ-2 to 9). CMS adopted the PHQ-2 to 9. The PHQ-2 to 9 is based on the first two symptoms addressed in the PHQ-9: depressed mood and anhedonia (inability to feel pleasure), which are the cardinal symptoms of depression. If a patient demonstrates signs of depressed mood and anhedonia under the PHQ-2, then the patient is administered the lengthier PHQ-9. The new items will be collected on the Initial Medicare Assessment and planned discharges.
    • Interim Payment Assessment (IPA). CMS states that they continue to believe that it is necessary for SNFs to continually monitor the clinical status of each and every patient in the facility regularly, regardless of payment or assessment requirements, and they believe that there should be a mechanism in place that would allow facilities to do this. CMS believes the IPA establishes one of the vehicles that the SNF can utilize in the course of carrying out its ongoing patient monitoring responsibilities.
    • Definition of Group Therapy. CMS has updated the definition of group therapy to align with In-patient Rehab Facility (IRF) regulations. Starting, October 1st, SNF group therapy will be defined in the RAI manual as “a qualified rehabilitation therapist or therapy assistant treating two to six patients at the same time who are performing the same or similar activities.”

SNF Value-Based Purchasing Program (VBP)

  • Change in The Program’s Measure Name. SNF VBP Program is changing the name of the program’s measure to the “Skilled Nursing Facility Potentially Preventable Readmissions after Hospital Discharge” measure. The measure will retain the same abbreviation (SNFPPR).
  • Update to the Public Reporting Requirements. To ensure accurate performance for low-volume SNFs, CMS is updating public reporting for SNFs with less than 25 eligible stays during the baseline period or performance period for a program year and for SNFs with zero eligible cases during the performance year.
  • Review and Correct Process. CMS is shortening the review and correct period to a deadline of 30 days for Phase One Review and Correction requests

SNF QRP

    • Transfer of Health Information Quality Measures. Effective 2022, there will be two new MDS process-based quality measures (QMs): Transfer of Health Information to the Provider-PAC and Patient-PAC will be added to SNF QRP. This will require the sharing of medication reconciliation information with next-level providers and the patient/family.  Data collection will begin October 1, 2020. A box will be added to the MDS to indicate if the information was shared.
    • Standardized Patient Assessment Data Elements. Since initially introduced in the FY 2018 SNF PPS Proposed Rule, CMS has been vetting proposed SPADEs through Technical Expert Panels and Open-Door Forums to ensure reliability and validity. Current MDS items along with a new data set to satisfy reporting of SPADEs has been finalized and includes the addition of 59.5 new data elements to the Initial Medicare Assessment (term being used to replace 5-day assessment) and Part A PPS Discharge Assessment starting with admission and discharges beginning October 2020.
    • Expand QRP to cover all payers. CMS proposed that SNF QRP no longer be limited to Part A fee-for-service but expanded to cover all SNF payers. This proposal was not adopted. It will continue to apply to Part A fee-for-service.
    • Exclusion of Baseline Nursing Home Residents. Effective FY 2020, base-line nursing home residents will be excluded from the claims-based Discharge to Community-PAC SNF QRP measure. Base-line nursing home residents are defined as “SNF residents who had a long-term NF stay in the 180 days preceding their hospitalization and NF stay, with no intervening community discharge between the NF stay and hospitalization.”  
    • Drug Regimen Review. CMS is finalizing its proposal to publicly display the quality measure, Drug Regimen Review Conducted with Follow-Up for Identified Issues.

    Melissa Ward
    Vice President of Clinical and Regulatory Affairs