On April 20, 2015, CMS published its proposed rule updating Medicare skilled nursing facility (SNF) PPS rates and policies for FY 2016. CMS projects that the proposed rule would increase overall payments to SNFs by $500 million, or 1.4%, compared to FY 2015 levels. This update would be attributed to a 2.6% market basket increase that would be reduced by a 0.6 percentage point forecast error adjustment and a 0.6 percentage point multifactor productivity adjustment.
The proposed rule also would implement a provision of the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) that reduces, by two percentage points, the annual update to SNFs that fail to submit required quality data to CMS under the SNF Quality Reporting Program (QRP), beginning with FY 2018. CMS is proposing to adopt three measures SNFs would be required to report beginning with the FY 2018 SNF QRP that address three quality domains identified in the IMPACT Act: (1) skin integrity and changes in skin integrity; (2) incidence of major falls; and (3) functional status, cognitive function, and changes in function and cognitive function. The proposed measures are intended to address the IMPACT Act requirement of standardized post-acute care data reporting across home health agencies, inpatient rehabilitation facilities, long term care hospitals, and SNFs. CMS intends to propose additional quality measures and resource use measures in future rulemaking.
Additionally, CMS proposes establishing a 30-day all-cause, all-condition hospital readmission quality measure that will be used in a new SNF Value-Based Purchasing (VBP) Program beginning with FY 2019, as required by the Protecting Access to Medicare Act of 2014 (PAMA). CMS notes that PAMA also requires CMS to specify an all-condition, risk-adjusted potentially preventable hospital readmission rate, which CMS intends to address in future rulemaking. CMS also seeks comments on numerous issues associated with the SNF VBP Program, which will be addressed in the FY 2017 SNF PPS proposed and final rules. In addition, the proposed rule would establish new regulatory reporting requirements for SNFs and nursing facilities to electronically submit staffing information based on payroll data, as mandated by the Affordable Care Act (ACA).
Comments on the proposed rule will be accepted until June 15, 2015.